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Privacy Policy

Final Phase 1 Draft - New Jersey Launch and United States Expansion
Effective Date: [MONTH DAY, YEAR]  |  Last Updated: [MONTH DAY, YEAR]

Phase 1 scope: This policy assumes users are 18+, the app collects only the minimum step data needed for rewards, does not use background location, does not upload contact lists, does not offer direct messaging, does not use targeted advertising, does not sell personal information, and does not offer crypto or employer wellness reporting during Phase 1.

1. Introduction

[FULL LEGAL COMPANY NAME], a [New Jersey LLC/corporation] doing business as WalkieGO ("WalkieGO," "we," "us," or "our"), respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you use:

Together, these are called the "Services." This Privacy Policy does not replace the WalkieGO Terms of Use, Rewards and Points Policy, Community Guidelines, Merchant Agreement or any separate promotion rules.

2. Company Information

3. Eligibility

WalkieGO is intended only for individuals who are at least 18 years old. We do not knowingly permit children under 18 to create accounts, and we do not knowingly collect personal information from children under 13. We may request a date of birth or age confirmation during account creation.

If we learn that an ineligible minor has created an account, we may:

A parent or guardian who believes that a minor provided information to WalkieGO may contact privacy@walkiego.com.

INFORMATION WE COLLECT

4. Account Information

When you create or manage an account, we collect:

We do not require your legal name to be publicly displayed. Other users see only the profile information that the application identifies as public.

5. Step and Walking Information

With your permission, WalkieGO collects the minimum walking information needed to calculate progress, Points, streaks and challenge participation. This may include:

Depending on the final application configuration, this information may come from:

Information we do not collect during Phase 1

Unless this policy is updated and you receive an appropriate disclosure, WalkieGO does not collect:

WalkieGO does not use information obtained through Apple Health, Motion and Fitness or similar connected fitness systems for advertising, marketing or unrelated data mining.

6. Location Information

WalkieGO uses location information only when needed for an enabled location-based feature.

Approximate location

We may collect or derive your general location, such as city, ZIP code or approximate geographic area, to:

Precise location

If you separately grant permission, we may access your current precise location:

Phase 1 location commitments

You may disable location permissions in your device settings. Some nearby-offer or redemption-verification features may then be unavailable.

7. WalkieGO Points and Reward Information

We collect information relating to:

WalkieGO Points are promotional loyalty units. They are not cash, cryptocurrency, investments, deposits or bank funds.

8. Merchant Interactions

When you view or redeem a merchant offer, we may collect:

We do not give merchants access to your:

9. Profiles, Leaderboards, Groups and Challenges

If you participate in social or competitive features, we may process:

Privacy defaults

For Phase 1:

WalkieGO does not use facial recognition and does not create biometric templates from profile photographs.

10. Referrals

WalkieGO may generate a personal referral code or referral link. We collect:

During Phase 1:

11. Payment and Subscription Information

If WalkieGO offers paid memberships, payments may be processed by Apple, Google or another identified payment processor. We may receive:

We do not receive or store full payment-card numbers when payment is handled entirely by an app store or independent payment processor. The payment provider processes payment information under its own privacy policy.

12. Device and Technical Information

We may automatically collect:

We do not collect persistent hardware identifiers such as IMEI or SIM serial numbers unless legally permitted and strictly necessary for a disclosed function.

13. Customer Support Information

When you contact WalkieGO, we collect information you provide, which may include:

Please do not send medical records, government identification numbers, payment-card details or unrelated sensitive information through customer support.

14. Fraud, Security and Compliance Information

We may collect or generate information relating to:

This information may be combined with relevant account, device, activity and redemption records to protect users, merchants and WalkieGO.

15. Information from Third Parties

We may receive information from:

The information received depends on your settings, permissions and the third party's practices.

HOW WE USE INFORMATION

16. To Provide the Services

We use personal information to:

17. To Personalize the Experience

We may use information to personalize:

We do not use sensitive fitness or precise-location information to create unrelated advertising profiles.

18. Communications

Essential communications

Optional communications

With the appropriate permission, we may send:

You may manage push notifications through the application or device settings and unsubscribe from marketing emails using the link provided in the message. We may continue to send essential legal, security and account-related notices.

19. Security and Fraud Prevention

We use information to:

20. Analytics and Improvement

We may use limited device, technical and usage information to:

Our analytics providers are not permitted to use WalkieGO step, health or precise-location information for advertising, unrelated profiling or their own independent purposes.

21. Legal and Compliance Uses

We may use information to:

22. Aggregated and De-identified Information

We may create aggregated or de-identified information that cannot reasonably be linked to a particular individual. We may use it to:

We do not attempt to re-identify properly de-identified information except to test whether our de-identification safeguards remain effective. Recipients of de-identified information must not attempt to re-identify it or combine it with other information for that purpose.

HOW WE DISCLOSE INFORMATION

23. Service Providers

We may disclose information to vendors that provide:

Service providers may process information only for contracted purposes and must protect it under applicable agreements.

24. Participating Merchants

We disclose only the information a merchant reasonably needs to validate or administer a reward, such as:

Merchants do not receive your full walking history, full location history, password, payment-card details or unrelated profile information.

25. Other Users

Other users may see only information made visible through the relevant feature and your settings, such as:

WalkieGO does not disclose your exact real-time location to other users.

26. Legal, Safety and Security Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

Where appropriate, we may challenge or narrow requests that are invalid, unlawful or excessive.

27. Business Transactions

Information may be transferred in connection with:

Any recipient remains subject to applicable privacy obligations and notices.

28. With Your Direction

We disclose information when you:

NO SALE OR TARGETED ADVERTISING

29. Our Phase 1 Commitments

WalkieGO does not:

We do not include a third-party advertising SDK in the Phase 1 mobile application. If these practices change, we will update this Privacy Policy, provide required notices and controls, and obtain consent where required before beginning the new practice.

COOKIES AND SIMILAR TECHNOLOGIES

30. Website Cookies

WalkieGO.com may use necessary cookies or similar technologies for:

Non-essential cookies will be handled through an appropriate consent or opt-out mechanism where required. A separate Cookie Notice will identify the actual cookies and website technologies used.

31. Mobile Tracking

WalkieGO does not track users across other companies' applications or websites for targeted advertising during Phase 1. If a future feature requires tracking governed by Apple's App Tracking Transparency framework or another consent requirement, WalkieGO will first present the required disclosure and request permission.

DATA RETENTION AND DELETION

32. Retention Principles

We retain personal information only for as long as reasonably necessary to:

Different records have different retention periods.

33. Phase 1 Retention Schedule

Subject to applicable law and legal holds:

Information categoryRetention period
Account profileUntil account deletion
Daily step totalsUntil account deletion or earlier user deletion where offered
Raw continuous motion dataNot uploaded or retained by WalkieGO
Precise location used for nearby searchProcessed transiently and not retained as location history
Redemption-verification locationUp to 30 days, unless required for an active fraud investigation
Approximate city/regionUntil changed or account deletion
Points and redemption historyUp to 7 years after the transaction where needed for accounting, fraud or disputes
Subscription transaction recordsUp to 7 years
Referral recordsUp to 3 years after the referral or longer during a fraud dispute
Customer-support recordsUp to 3 years after closure
Security and login logsUp to 12 months
Fraud and enforcement recordsUp to 7 years after final resolution
Marketing preferencesUntil changed, plus a suppression record to honor the choice
Deleted-account backupsRemoved through the routine backup cycle, normally within 90 days
Legal-hold informationUntil the legal hold or dispute ends

If engineering cannot implement these periods, the policy must be changed before launch. WalkieGO will not publish retention promises that the system cannot honor.

34. Account Deletion

You may initiate full account deletion inside the application:

Settings -> Account -> Delete Account

You may also contact privacy@walkiego.com. Account deletion will remove or de-identify personal information that WalkieGO is not legally required to retain. We may retain limited information for:

35. Account Deletion and Subscriptions

Deleting a WalkieGO account may not automatically cancel an Apple App Store or Google Play subscription. Before deletion, we will explain how to cancel an active subscription through the applicable app store. Deletion of the WalkieGO account does not automatically create a refund right.

YOUR PRIVACY CHOICES

36. Account and Profile Controls

You may:

37. Device Permissions

You may control permissions through your device settings, including:

Revoking permission stops future access through that permission but does not automatically delete information previously collected.

38. Health and Fitness Connections

You may disconnect Apple Health, Motion and Fitness, Google Health Connect or a supported wearable through the applicable service or device settings. You may separately request deletion of information already received by WalkieGO.

39. Marketing Choices

You may:

We may still send security, legal, account and transactional communications.

UNITED STATES PRIVACY RIGHTS

40. Rights We Offer

Subject to verification, legal exceptions and technical feasibility, WalkieGO provides users in the United States with the ability to request:

Because WalkieGO does not sell personal information or use it for targeted advertising during Phase 1, no sale or targeted-advertising opt-out is required for the current business model. We will provide appropriate controls before introducing such a practice.

41. New Jersey Residents

Where New Jersey privacy law applies, New Jersey residents may have rights to:

WalkieGO limits personal-data collection to information that is adequate, relevant and reasonably necessary for disclosed purposes and does not use information for incompatible purposes without appropriate consent.

42. California and Other States

Depending on WalkieGO's operations, legal thresholds and your state of residence, additional privacy rights may apply. WalkieGO may provide state-specific supplemental notices as laws and services change. Nothing in this Policy reduces rights that cannot legally be waived.

43. Submitting a Privacy Request

Submit a request through:

44. Identity Verification

We may verify your identity by:

We will not request more information than reasonably necessary for verification.

45. Authorized Agents

Where applicable law permits, an authorized agent may submit a request for you. We may request:

46. Response and Appeals

We will respond within the period required by applicable law. Where an appeal right applies, you may appeal a denied request by emailing privacy-appeals@walkiego.com. Include the original request reference and the reason you believe the decision should be reconsidered.

47. Non-Discrimination

We will not unlawfully discriminate against you for exercising privacy rights. Disabling information essential to a feature may prevent that feature from functioning. For example, WalkieGO cannot calculate walking Points without receiving eligible step information. This is a functional limitation, not retaliation for exercising a privacy right.

HEALTH AND FITNESS PRIVACY

48. HIPAA

WalkieGO is designed as a consumer walking and rewards platform, not as a healthcare provider, health plan or healthcare clearinghouse. WalkieGO is not intended to provide medical care or maintain clinical medical records. However, other federal or state privacy and consumer-protection laws may still apply to fitness information even when HIPAA does not.

49. FTC Health Breach Notification Rule

Because WalkieGO may receive identifiable fitness information from a user and a connected fitness source, the FTC Health Breach Notification Rule may apply depending on the final technical configuration. If the Rule applies, WalkieGO will evaluate and satisfy applicable notification obligations following an unauthorized acquisition or disclosure of unsecured identifiable health information. WalkieGO maintains an incident-response process to evaluate and satisfy applicable breach-notification requirements.

SECURITY

50. Safeguards

WalkieGO uses reasonable administrative, technical and organizational safeguards appropriate to the sensitivity of the information processed. At launch, these safeguards include:

No information system can be guaranteed completely secure.

51. Security Incidents

If a security incident affects personal information, we will:

WalkieGO requires relevant service providers to notify it promptly of security incidents involving WalkieGO information.

52. User Responsibilities

You should:

CHILDREN'S PRIVACY

53. Underage Accounts

WalkieGO is not intended for users under 18. We do not knowingly collect personal information from children under 13.

If we become aware that a minor provided information in violation of our age rules, we will take reasonable steps to suspend the account and delete information where required. We will not:

FUTURE FEATURES

54. Features Not Included in Phase 1

The following are not offered under this Privacy Policy during Phase 1:

If WalkieGO introduces one of these features, we will update this Policy and provide additional disclosures or consent before collecting information for the new purpose.

CHANGES AND CONTACT

55. Changes to This Privacy Policy

We may update this Policy to reflect:

We will update the "Last Updated" date. For material changes, we will provide notice through one or more of:

Where required, we will obtain affirmative consent before applying a materially different use to sensitive information previously collected.

56. Contact Us

Questions, complaints or privacy requests may be sent to:

WalkieGO / [FULL LEGAL COMPANY NAME]

[FULL BUSINESS ADDRESS]

New Jersey, United States

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