PRIVACY POLICY

 

Last Updated: June 25, 2024


Hi there! Welcome to WALK!

We are committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. 

Capitalized terms not defined here have the meanings set forth in the Terms of Service (the “Terms”), located at www.walklongevity.com/terms. By using or accessing the Services, you agree to the contents of this Privacy Policy and agree to abide by the Terms.

This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you through your use of the Services.


I. COLLECTION OF INFORMATION

We collect the following categories of information when you use our Services (including when you download or launch our mobile application, or when the application is running on your device in the background):

Information you provide directly to us, including by allowing us access.

  • Identification Data: We collect your name, email address, and unique identifiers assigned by third party platforms (such as analytics or communication tools). If you sign up using credentials from a third party account such as Apple or Google, we may collect your name and email address from the applicable third party.
  • Walking Data: We collect information relating to your walking activity, such as the number of steps, active stepping minutes, and active stepping distance.
  • Health Data: We may collect your resting heart rate, heart rate variability, activity, weight, and sleep data, either directly from you or from Apple Health or Android Health Connect, if you choose to provide such information. Notwithstanding anything else in this Privacy Policy, (a) we use Health Data only to provide the Service and not for advertising and (b) we will not disclose Health Data for advertising, marketing, or use-based data mining not needed to provide the Service. 
  • Communication Data: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback.  Providing this information is optional to you.
  • Demographic Data: We may collect your birthdate and gender if you choose to provide them during sign-up.
  • Social Media Data: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Identification Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Information we collect automatically.  

When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

  • Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. Such Log Data is also collected when you interact with the App.
  • Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.
  • Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
  • Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
  • Location Data: We may derive a rough estimate of your location from your IP address. We may also collect your location using GPS coordinates if you choose to provide it through the App.
  • Email Open/Click Data: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Without this information, we are not able to provide you with all the requested Services, and any differences in Services provided are related to your information. 

We may aggregate or de-identify the information described above.  Aggregated or de-identified data is not subject to this Privacy Policy.


II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above for the following business purposes to provide and maintain the Services, and other products or services you request:

  • To help you track your health habits, display your progress over time, and suggest behavioral adjustments;
  • To verify your identity, age, and contact details;
  • To authenticate your access to the Service;
  • To personalize the Service for you;
  • To provide disclaimers based on your Health Data to ensure your safety while using the Service;
  • To respond to your inquiries, comments, feedback, or questions;
  • To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
  • To otherwise provide and maintain the Service, including to improve the Service and to analyze and better understand how you interact with our Service;

We also use and otherwise process each of the categories of information identified above for the following business purposes:

  • To show you advertisements, including interest-based or online behavioral advertising;
  • To develop new products and services;
  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.


III. DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

  • Authorized third-party vendors and service providers. We share the information you provide directly to us and the information we collect automatically with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, analytics, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
  • Business transfers. We may share the information you provide directly to us and the information we collect automatically in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
  • Legal purposes. We may disclose any of the information that we collect to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Company, our affiliates, users, or the public.
  • With your consent. We may share the information that we collect for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

If you access third-party services -- such as social media services or other health apps -- through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies. 

If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

Company does not sell your information to third parties or share your information for the purposes of cross-context behavioral advertising. 

We do not use or disclose sensitive data for any purpose other than those permitted by applicable law.


IV. COOKIES AND SIMILAR TECHNOLOGIES

When you use our Services, we and our third party advertising partners use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”). Cookies are small files placed on the hard drive of your computer that collect information from your browser or device. 

The following types of cookies are used on our Services:

  • Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, certain services cannot be provided. These cookies also help keep our Services safe and secure.
  • Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you've previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
  • Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly, which device and/or website you come from, and any error messages that appeared during your use of the Services. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
  • Content / advertising cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising on our Services. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our Services and help us understand usage of our Services. 

Do-Not-Track Signals and Similar Mechanisms. 

Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Personal Information Collected Through Cookies.

We use the personal information collected through cookies for the purposes specified above (including in the Section “Use of Information and Purpose of Data Processing”).

Please read the next Section (“Your Rights and Choices”) for information on how to manage cookies.


V. YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.

Requests should be submitted in writing as set out. Once we receive your request, we will verify it by matching the data you provide with the data in our system. You also may be entitled, in accordance with applicable law, to submit a request through an authorized agent. 

If you have previously verified your email address with Company, you also have the option to delete your data and profile via the app. To delete your data and account, go to the Me tab, then Settings, then Edit Profile and tap on the ‘Delete My Account’ button. Upon confirming the request within the app, you will be signed out of the product immediately and your data will be deleted. This process is irreversible and you will no longer be able to login to the app with your account. You can, however, create a new account with that email address. 

You may be able to refuse or disable cookies by adjusting your web browser settings.  Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). With regards to some of the popular browsers you can find more information by clicking on the following relevant links: Google Chrome; Microsoft Edge; Mozilla Firefox; Microsoft Internet Explorer and Apple Safari.  

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you. Any differences in the Services are related to the value provided.  


‍VI. INTERNATIONAL TRANSFERS

We may transfer and store your information on servers located outside your resident jurisdiction.  To the extent you are a resident of a country other than the United States, UK or EEA, you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA or UK, including in countries that may not provide the same level of data protection or redress means as your home country.  We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality.


VII. CHILDREN

We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.  The service is not directed at children.‍


VIII. CONSUMER HEALTH DATA POLICY

The privacy of information that identifies your physical or mental health status is important to us. As described above in “Collection of Information,” we may collect categories of data that may be considered “consumer health data” under Washington’s My Health My Data Act and other similar state laws when you interact with our Services, including:

  • Information about your bodily functions, vital signs, symptoms, or measurements; and
  • Information about your health conditions, treatment, diseases, or diagnosis.

 For additional details about the types of data we collect and how we collect it, please review “Collection of Information” in the Privacy Policy.

We use and otherwise process each of the categories of information identified above for the following business purposes, to provide and maintain the Services, and other products or services you request.

We use Health Data only to provide the Service, including to support, improve, and administer the Services.  Please review “Use Of Information and Purpose of Data Processing” in the Privacy Policy for additional details. Notwithstanding anything else in this Privacy Policy, we do not use Health Data for advertising, and we will not disclose Health Data for advertising, marketing, or use-based data mining not needed to provide the Service without your consent.

We may share personal information, including each of the categories of consumer health data, as reasonably necessary to provide you the Services, including with service providers or business partners in connection with a sale, merger, or other business transfer, for legal reasons.  For additional details about how we share information, please review “Disclosure of Information.”

You may be entitled to, in accordance with applicable law, submit a request to know, access, correct or delete the information we have collected about you. Please review “Your Rights And Choices” to exercise these rights.


IX. DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

We implement technical, physical, and organizational measures and controls, such as encryption, to safeguard and protect the transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity.

We maintain reasonable security measures to safeguard information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.

Please be aware that despite our efforts, we cannot guarantee absolute security of your account or information. In addition, you can take steps to protect your account and information such as creating a unique password that is not easily guessed and that you don't use anywhere else, not sharing your password with others, and promptly reporting suspicious activity or unauthorized account access.


X. CHANGES TO THE PRIVACY POLICY

We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Last Updated” date above and post the new Privacy Policy.  We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.


XI. CONTACT INFORMATION

If you have any questions about this Privacy Policy or our practices, please contact us at team@walklongevity.com.