1. Introduction
Waltoria LLC, a Nebraska limited liability company ("Waltoria," "we," "us," or "our"), is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and protect information about you when you use our services, visit our website at waltoria.io, or otherwise interact with us.
Waltoria is a financial services firm based in Nebraska, providing financial advisory services, insurance products, and technology-enhanced financial planning tools. Insurance products are offered through our principal, Ifeanyi Onubogu, under their individual insurance producer license (Nebraska, NPN 20352929), and in another state only where they hold a producer license in that state.
Waltoria delivers its services with the help of artificial-intelligence (AI) tools. Section 5.7 explains what that means for your information.
By using our services or providing us with your personal information, you acknowledge that you have read and understand this Privacy Policy.
2. Information We Collect
2.1 Information You Provide
We collect information you provide directly to us, including:
Contact Information
- Full name
- Email address
- Phone number
- Mailing address
- ZIP code
Financial Information
- Income and employment details
- Assets and liabilities
- Investment accounts (via Plaid integration)
- Insurance policies and coverage
- Retirement account information
- Tax filing status
Demographic Information
- Date of birth
- Marital status
- Number of dependents
- Homeownership status
Business Information (for business clients)
- Business name and structure
- Business contact information
- Role and decision-making authority
- Number of employees
- Annual revenue
Family Information (when relevant to financial planning)
- Spouse/partner information
- Dependent information
- Beneficiary designations
2.2 Information Collected Automatically
When you visit waltoria.io we automatically collect:
(a) Page-visit records, measured by us. For each page you view we record the page address without any search or query text, the date and time, how you reached us (for example a search engine, an AI assistant, another website, or the name of an email or advertising campaign), the name but never the value of any advertising click identifier in the link when it is recorded in this record, whether you are using a phone, tablet or computer, and whether the visit appears automated. We do not store your IP address, your browser's full identification string, your location, or anything you type in this record. Each record from your browser carries a browser identifier that we generate and keep in a first-party cookie and in your browser's storage, so we can tell visits from the same browser apart. This identifier is not your name, but it is not anonymous either: see (b).
(b) If you give us your details — for example by starting a quote, using a calculator, subscribing, or clicking a personalised link in an email from us — we connect that browser's earlier and later page-visit records to your record. We use them to understand which pages and marketing channels led you to us and to prepare for our follow-up with you. We do not connect them by IP address, browser fingerprint or information from other companies. We do not give them to advertising platforms or data brokers, we do not sell them, and we do not use them to decide whether to offer you a product or what to charge.
(c) Our hosting providers. Each time you view a page, your browser contacts our servers directly, and our hosting providers see your IP address and your browser's full identification string as part of delivering the site, preventing abuse and fixing errors. Our hosting providers keep request logs, which we do not control, that can include your IP address and your browser's full identification string, for a limited period that depends on the provider and its plan. Our website also writes a shortened form of your browser's identification string to its request log at Vercel, to help us tell automated traffic from people. Our own servers also keep your IP address in memory, for no more than about two minutes after your most recent page view, to limit abuse of the page-visit measurement, and do not add it to your page-visit record or to our own logs of these requests. We do not match those provider logs to your page-visit record.
(d) Website measurement services. We use Vercel Web Analytics, a cookieless service that reports aggregate visits and approximate location, and Vercel Speed Insights, which reports how quickly our pages load. We also use Google Analytics, operated by Google, with advertising cookies, advertising use of your data and ad personalisation turned off; it receives the address of each page you view, including any campaign tags or advertising click identifier in the link. If you choose Accept in our cookie banner, Google Analytics uses cookies to measure your visit. Until you make a choice, and if you decline Google Analytics, it sets no Google Analytics cookies, but your browser may still send Google cookieless measurement requests, which reach Google with your IP address like any other request to Google.
(e) When you start a form or send us something. When you open our get-started form, use a calculator, sign up for our newsletter, submit a request, follow a personalised link in an email from us, give us consent to contact you, or sign a document with us, we may record the IP address and browser identification string of that request, together with how you reached us as held in the wlt_attr cookie (including the value of any advertising click identifier your link carried). When you have given us your details, we keep this information with your record, as evidence of your request, consent or signature and of the marketing that led you to us.
2.3 Information from Third Parties
We may receive information about you from third parties, including:
Financial Data Aggregators
- Account balances and transactions (via Plaid)
- Investment holdings
Insurance Carriers
- Policy status and details
- Underwriting information
- Claims history (when relevant)
Public Sources
- Publicly available information
- Professional networking profiles (LinkedIn)
3. How We Use Your Information
3.1 Providing Financial Advisory Services
We use your information to:
- Analyze your financial situation
- Develop personalized financial recommendations
- Process insurance applications on your behalf
- Prepare financial illustrations and proposals
- Manage our client relationship with you
- Use AI tools, under contract and with review by our professionals, to analyze your information and draft our work for you (Section 5.7)
3.2 Communications
We use your information to communicate with you, including:
Service Communications
- Appointment reminders and confirmations
- Application status updates
- Policy documents and disclosures
- Account notifications
SMS Text Messages (with your consent)
- Appointment reminders
- Service updates and notifications
- Follow-up communications
- Important alerts
Email Communications
- Transactional emails
- Service-related information
- Marketing communications: newsletters and similar mailings you sign up for, and occasional business outreach; every marketing email includes a way to unsubscribe
Phone Calls
- Consultation calls
- Follow-up discussions
- Service inquiries
3.3 Business Operations
We use your information for:
- Improving our services
- Analyzing service usage and effectiveness
- Complying with legal and regulatory obligations
- Preventing fraud and ensuring security
- Training and quality assurance
4. SMS Text Message Communications
4.1 Consent and Opt-In
If you provide your phone number and consent to receive SMS text messages, you agree to receive recurring automated text messages from Waltoria. Your consent is obtained through:
- Checking the SMS opt-in checkbox on our website forms
- Providing verbal consent during phone consultations
- Responding to a text message opt-in request
Consent is not required to purchase any services from Waltoria.
4.2 Types of Messages
You may receive the following types of SMS messages:
- Appointment reminders and confirmations
- Service updates and notifications
- Follow-up communications regarding your financial planning
- Important alerts about your applications or policies
- Responses to your inquiries
4.3 Message Frequency
Message frequency varies based on your interactions with us. You can typically expect:
- 2-5 messages per month during active engagement
- Periodic messages for appointment reminders
- Occasional service updates
4.4 Costs
Message and data rates may apply. Your carrier's standard messaging rates will apply to messages you send and receive. Contact your wireless carrier for details about your messaging plan.
4.5 Opting Out
You may opt out of SMS messages at any time by:
- Replying STOP to any message from us
- Emailing us at privacy@mail.waltoria.io
- Telling us in any other reasonable way, for example by phone or by replying to one of our emails
We will process your opt-out request within 10 business days. You may receive one confirmation message after opting out.
4.6 Help
For help with SMS messages:
- Reply HELP to any message from us
- Email: privacy@mail.waltoria.io
4.7 SMS Data Retention
In accordance with the Telephone Consumer Protection Act (TCPA), we retain records of SMS consent for a minimum of four (4) years, including:
- Consent timestamp
- Consent method (web form, verbal, etc.)
- Phone number
- Opt-out requests and timestamps
5. Information Sharing and Disclosure
5.1 Service Providers
We share information with third parties who provide services on our behalf, including:
| Provider Type | Purpose | Data Shared |
|---|---|---|
| Insurance Carriers | Policy issuance, underwriting | Application data, financial info |
| Plaid | Connecting financial accounts you choose to link | Details needed to set up the connection (you sign in to your bank through Plaid; we never receive your bank login) |
| Twilio | SMS communications | Phone number, message content |
| Resend | Email communications | Email address, message content |
| Vercel | Website hosting and measurement | Website requests, including your IP address, and analytics data |
| Railway | Hosting for our servers | Website and form requests, including your IP address and browser identification string |
| Supabase | Database hosting | The information we keep about you, including page-visit records |
| Anthropic, PBC (Claude AI models) | Analyzing your information and drafting our work for you: summaries of your household or business, reviews of your insurance and coverage, plans and recommendations for our professionals to review, reading documents you upload, and, for a Marketplace (HealthCare.gov) application, plan comparisons and application checklists (Section 5.7) | The information you give us for the service you asked for, with Social Security numbers, account numbers and similar identifiers removed. Tax return information only as Section 5.8 says. From a Marketplace (HealthCare.gov) application, only what the task needs, and never your name, Social Security number, contact details or account numbers |
| Website measurement (Google Analytics) | Pages you view, device information and your IP address; Google Analytics cookie identifiers if you choose Accept | |
| Stripe | Payment processing | Name, email and the payment details you enter with Stripe |
| Cal.com | Appointment scheduling | Name, email, appointment details |
Our service providers are required by contract to protect your information. Insurance carriers also use the application information they receive under their own privacy notices, and Google uses the information it receives through Google Analytics under Google's terms.
5.2 Legal Requirements
We may disclose your information when required by law, including:
- Court orders and subpoenas
- Regulatory examinations and inquiries
- Government requests
- Fraud investigations
5.3 Business Transfers
If Waltoria is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.
5.4 With Your Authorization
We share information with third parties when you authorize us to do so, such as:
- Designated beneficiaries
- Family members you authorize
- Other financial professionals at your request
5.5 Information We Do Not Sell
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
5.7 How We Use AI to Deliver Our Services
AI is part of how Waltoria works. For most services, our own AI agent service uses Claude, the AI models made by Anthropic, PBC, to analyze the information you give us and draft our work for you: for example, a summary of your household's or business's finances, a review of your life, disability, health or other insurance and your coverage contracts, a financial plan, a debt strategy or a business plan.
What we send. Only what the task needs, for you alone. We remove Social Security numbers, taxpayer identification numbers, full bank, brokerage and card account numbers, PINs and passwords before anything is sent. We send health information only to carry out an insurance service for you, such as reviewing your coverage. From a Marketplace (HealthCare.gov) application or enrollment, we send only what is needed for the tasks our Marketplace Privacy Notice lists, such as preparing plan comparisons and application checklists, and never your name, Social Security number, contact details or account numbers. A licensed agent reviews everything before it is used.
The contract. Anthropic processes what we send under its commercial terms and data processing addendum. It may use it only to provide its service to us, and may not train its models on it. Processing takes place in the United States. Anthropic deletes what we send within 30 days, except that it may keep material its automated safety systems flag for up to two years, and anything the law requires it to keep. We do not use any consumer AI account or subscription for your information.
Our professionals stay responsible. AI drafts; people decide. A Waltoria professional reviews every AI-assisted analysis, recommendation and document before we rely on it or send it to you. Our own software, not AI, computes the figures on a tax return and in tax planning. No AI tool talks with you about your taxes, insurance or finances, and anything we give you that AI helped prepare says so.
Mistakes. AI can state facts that are wrong. That is why our professionals check its work before we rely on it. If anything we send you looks wrong, please tell us.
Your choices. Using AI in this way is part of the service you ask us for, in the same way as our other service providers in Section 5.1, and the law does not give a right to opt out of it. If you would rather we did not use AI on your information, tell us before we begin: we will tell you whether we can provide the service you want without it, and on what terms.
5.8 Tax Return Information
Information you give us to prepare your tax return is also protected by federal law (Internal Revenue Code section 7216). We disclose it to an AI provider only under the separate written forms you sign. To prepare your return, we use AI under one such form, the Consent to Disclose Tax Return Information to Prepare Your Return with AI, which is part of our return preparation service; your engagement letter explains what happens if you do not sign it. Any other use of your tax return information, or disclosure of it to an AI provider, for example for tax planning, is optional and needs its own forms. What you tell us for tax planning, separately from preparing your return, is handled as Section 5.7 describes.
6. GLBA Privacy Compliance
As a financial services provider, we comply with the privacy provisions of the Gramm-Leach-Bliley Act (GLBA) that apply to our business, including the Nebraska Privacy of Insurance Consumer Information Act and the insurance privacy laws of the other states where our principal holds a producer license.
6.1 Categories of Nonpublic Personal Information (NPI)
We collect the following categories of NPI:
- Information you provide on applications (name, address, income, assets)
- Information about your transactions with us (products purchased, account activity)
- Information from consumer reporting agencies (credit history, if applicable)
- Information about your use of our website after you ask us for a product or service (for example, the pages you viewed before and after you requested a quote), when we connect it to your record
6.2 Information Sharing Practices
Affiliates: Waltoria does not currently have affiliated companies with which we share NPI.
Non-affiliated Third Parties: We share NPI with non-affiliated third parties only:
- As permitted by law (e.g., to process transactions, maintain accounts)
- With your consent
- As described in this Privacy Policy
- With service providers that perform services for us under contracts that limit their use of your information, including the AI provider described in Section 5.7
Joint Marketing: We do not engage in joint marketing arrangements that would require sharing your NPI with other financial institutions.
6.3 Your Right to Opt-Out
Because we do not share your NPI with non-affiliated third parties for marketing purposes, there is currently no need for you to opt out. If our practices change, we will provide you with an opt-out notice and opportunity. Sharing with service providers that work for us under contract, including the AI provider in Section 5.7, is not sharing that federal or Nebraska law lets you opt out of.
7. Insurance Privacy (IIPPA/NAIC)
7.1 Insurance Information We Collect
In connection with insurance products, we may collect:
- Application information (health history, lifestyle factors)
- Information from insurance support organizations
- Consumer reports (with your authorization)
- Information from medical professionals (with your authorization)
7.2 Disclosure of Insurance Information
We may disclose insurance information:
- To insurance companies for underwriting and policy issuance
- To reinsurers
- To medical professionals for underwriting verification
- To service providers that perform insurance functions for us, such as the AI provider that helps us review your coverage and prepare your recommendations, under contracts that limit their use of the information to those functions (Section 5.7)
- As otherwise permitted by applicable state insurance laws
7.3 Your Rights Under Insurance Privacy Laws
You have the right to:
- Access personal information in your insurance file
- Request correction of inaccurate information
- Receive reasons for adverse underwriting decisions
- Know about disclosures made in the past two years
To exercise these rights, contact us at privacy@mail.waltoria.io.
8. Data Security
8.1 Technical Safeguards
We implement technical measures to protect your information:
- Encryption of data in transit (TLS/SSL)
- Encryption of sensitive data at rest
- Secure authentication mechanisms
- Regular security assessments and updates
- Access logging and monitoring
8.2 Administrative Safeguards
We maintain administrative controls including:
- Employee training on privacy and security
- Background checks for employees with data access
- Vendor due diligence and contractual protections
- Incident response procedures
- Regular policy reviews
8.3 Physical Safeguards
We protect physical access to systems containing your data through:
- Secure cloud infrastructure (Vercel, Supabase)
- Access controls at physical locations
- Secure device management
8.4 Data Breach Response
In the event of a data breach involving your personal information, we will:
- Investigate and contain the breach promptly
- Notify you as applicable state breach-notification laws require, and in any case within 30 days after we confirm the breach
- Provide information about steps you can take
- Report to regulators as required by law
9. Data Retention
9.1 Retention Periods
We retain your information for the following periods:
| Data Type | Retention Period | Basis |
|---|---|---|
| Client records | Duration of relationship + 7 years | Regulatory requirement |
| Insurance applications, other than Marketplace applications | 7 years after decision | Industry standard |
| Marketplace (HealthCare.gov) applications and their records, including your consent and the recordings of those calls | At least 10 years | Federal requirement (45 CFR 155.220(j); our agreements with CMS) |
| SMS consent records | 4 years | TCPA requirement |
| Financial data | Duration of relationship + 7 years | Business and regulatory needs |
| Website page-visit records | 13 months from the visit, then deleted. Encrypted backup copies roll off within 35 days after that. | Analytics purposes |
| Daily visit totals with no identifiers | Kept indefinitely | Analytics purposes |
| Marketing consent | Until withdrawal | Consent-based |
9.2 Secure Destruction
When retention periods expire, we securely destroy information through:
- Secure deletion of electronic records
- Shredding of physical documents
- Certification of destruction where required
10. Your Rights and Choices
10.1 Access and Correction
You have the right to:
- Request access to your personal information
- Correct inaccurate information
- Receive a copy of your information
To make a request, email privacy@mail.waltoria.io.
You may ask for a copy or deletion of the page-visit records connected to your record by writing to privacy@mail.waltoria.io. We cannot locate page-visit records that are not connected to a record with us. Clearing your browser's site data resets the identifier.
10.2 Communication Preferences
You can manage your communication preferences:
Email: Click "unsubscribe" in marketing emails or email privacy@mail.waltoria.io
SMS: Reply STOP to opt out of text messages
Phone: Request to be added to our do-not-call list
Mail: Request removal from physical mailings
10.3 Account Deletion
You may request deletion of your account and personal information. Note that we may be required to retain certain information for:
- Legal and regulatory compliance
- Fraud prevention
- Resolving disputes
- Enforcing agreements
This includes the page-visit records connected to your record; see Section 10.1.
11. Children's Privacy
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn that we have collected information from a child under 18, we will delete that information promptly.
13. Third-Party Links
Our website may contain links to third-party websites, including:
- Insurance carrier websites
- Cal.com (scheduling)
- Plaid (financial connections)
These websites have their own privacy policies. We are not responsible for their privacy practices.
14. State-Specific Rights
14.1 Nebraska Residents
As a Nebraska-based company, we comply with Nebraska consumer protection laws. Nebraska residents have the rights described in this Privacy Policy.
14.2 California Residents
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including:
- Right to know what personal information we collect
- Right to delete personal information
- Right to opt-out of sale of personal information (we do not sell your information)
- Right to non-discrimination for exercising privacy rights
To exercise CCPA rights, email privacy@mail.waltoria.io.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the "Last Updated" date at the top
- Post the revised policy on our website
- Announce the change on our website and on our social media channels (LinkedIn and Facebook), and notify affected people directly where the law requires it
Your continued use of our services after changes become effective constitutes acceptance of the revised policy.
16. Contact Us
If you have questions about this Privacy Policy or our privacy practices:
Email: privacy@mail.waltoria.io
Location: Waltoria LLC, Papillion, Nebraska
Website: https://waltoria.io/privacy
17. GLBA Privacy Notice
What Does Waltoria Do With Your Personal Information?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
- Social Security number and income
- Account balances and transaction history
- Credit history and employment information
When you are no longer our customer, we continue to share your information as described in this notice.
How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Waltoria chooses to share; and whether you can limit this sharing.
| Reasons we can share your personal information | Does Waltoria share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes — to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | No | We don't share |
| For our affiliates' everyday business purposes — information about your transactions and experiences | No | We don't share |
| For our affiliates' everyday business purposes — information about your creditworthiness | No | We don't share |
| For our affiliates to market to you | No | We don't share |
| For nonaffiliates to market to you | No | We don't share |
Questions? Email privacy@mail.waltoria.io
Other important information. We use service providers that handle your information for us under contracts that limit their use of it. They include Anthropic, PBC, whose Claude AI models help us analyze your information and draft our work for you; a Waltoria professional reviews that work before we rely on it or send it to you (see Section 5.7). This is part of our sharing "for our everyday business purposes" in the table above.
This Privacy Policy is effective as of October 23, 2026.