PRIVACY POLICY

SocialWalk Inc.

Version 2.0

Last Modified: 01/31/2023

1. POLICY PURPOSE

SocialWalk Inc., a company incorporated in Delaware (registration number 6958405) whose registered office is at c/o Harvard Business Services, Inc., 16192 Coastal Highway, Lewes, Delaware 19958, USA (“SocialWalk”, “we”, “our”, and “us”).

This Privacy Policy (“Policy”) informs you of our policies on how we collect, use, store, and share your information which on its own, or in combination with other information, may be used to identify you as an individual (“Personal Data”) and the choices you have associated with that data when you use the SocialWalk website https://socialwalk.us (the “Website”) and mobile application (the “App”), collectively referred to as the “Service”. This Policy does not apply to the practices of third parties that SocialWalk does not own or control or to individuals that SocialWalk does not employ or manage.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Policy where we are acting as a data controller of your Personal Data. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions (https://socialwalk.us/tnc/).Please carefully read the provisions of this Privacy Policy. Do not hesitate to contact us at support@socialwalk.us if you have any questions or want to discuss this Policy.

2. INFORMATION COLLECTED BY SOCIALWALK

SocialWalk obtains Personal Data that you provide when you download and register the App. When you register with us and/or sign up for an account through the App, you will be required to create a password. You generally provide (a) your name, email address, mobile phone number and other registration information; (b) your date of birth and pronouns; (c) information you provide us when you contact us for help; and (d) information that is entered into our system when you use the App, such as your Usage data or other Personal data (“User Provided Data”). 

Please note that, with your consent, we will collect information about your steps or other of your activities necessary for donating StepCoins to the campaigns. You may turn publishing of steps and/or donated StepCoins on and off using the Privacy Controls settings within the App.

In addition, as you use the Service, you may choose to provide additional Personal Data, including access to camera, photos, and contacts. Further, the Service allows you to post content on the Service through functions such as chat and comments and we collect this information, which can be considered Personal Data. You may provide the foregoing Personal Data by entering it into the Service, or through a third party service.

We may also use the information that you provide to us to contact you from time to time to provide you with important information, required notices, and marketing promotions. Important information can range from changes in our Terms and Conditions to changes that may affect your data. Users can opt out of marketing promotions.

We work with third parties from time to time including, for example, Apple HealthKit, Google Fit, business partners including but not limited to corporate donors, nonprofits and foundations (“Partners”), analytics providers and search information providers who may provide us with information about you.

3. USE OF INFORMATION COLLECTED BY SOCIALWALK

In general, Personal Data you submit to us is used either to respond to requests that you make or to aid us in providing you with the core aspects of the Service. Some of the ways we use your Personal Data include, but is not limited to: (a) facilitate your account creation as part of account setup procedure; (b) verify your identity and identify you as a user on our platform; (c) improve the quality of user experience; (d) create daily leader boards of users, comprising all users or users meeting particular criteria as ranked by the number of steps counted or StepCoins donated; (e) identify the users with the highest number of steps counted or StepCoins donated and award them with prizes; (f) connect you with other users and allow you to invite contacts to use the Service; (g) investigate and/or prevent suspected fraud or other criminal activities; (h) resolve errors and problems with the Service; (i) analyze the usage of the Service; (j) send you administrative email notifications, such as security or support and maintenance advisories; and (k) send newsletters, surveys, offers, and other promotional materials related to our App and for other marketing purposes of SocialWalk.

By using our App, you consent to our processing of your Personal Data and User Provided Data as described in this Privacy Policy currently and as amended by us. Processing means using data collected on a computer or mobile device, or touching information in any way, including but not limited to, using, collecting, storing, deleting, combining and disclosing information.

The legal bases for processing your Personal Data, where we are acting as a data controller, include, but are not limited to: (1) the processing is based on the performance of a contract in which you provided your consent by agreeing to this Privacy Policy; (2) the processing is required for our contractual relationship with you meaning we need to process your Personal Data to be able to provide you with the Service that we have agreed to (our Terms and Conditions); (3) the processing is in our legitimate interest to make our App social and competitive and provide visibility on how you rank against other users and encourage you to walk more; (4) the processing is in our legitimate interest to allow you to interact with friends through the App; (5) the processing is necessary for us to be compliant with our legal or regulatory obligations; and (6) the processing is in our legitimate interest as a provider of the Service (for example, to protect the security and integrity of our systems and data and to provide you with customer service and the core functionality of the Service).

4. TO WHOM WE SHARE YOUR PERSONAL DATA WITH

We may share your Personal Data with the following recipients as necessary for certain purposes as described above and as further described below. 

SocialWalk Personnel and Affiliates: We may disclose your Personal Data to our personnel, including our employees, contractors, and agents, to the extent that such persons or entities have a need-to-know such information if necessary in the normal course of SocialWalk business and/or research to provide you with the Service, and to improve the functionality of the Service. This means that user information, including name, address, phone number may be used for the following reasons: responding to user requests, ensuring smooth operation of the App, and/or modifying our product to increase users’ success rates. We may solicit your participation in conducting research and developing user case studies.

Third Parties/ Service Providers: SocialWalk employs third parties to perform functions on our behalf. Examples include hosting or operating the SocialWalk website, application development, hosting, maintenance, sending email and/or other communications, data processing, data analysis, marketing assistance, customer service, and other services. These service providers may have access to your Personal Data for the purpose of performing such functions for us. However, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions and we have agreements in place, pursuant to which they are required, amongst other things, to maintain the confidentiality of the Personal Data. 

Charitable Organizations and Corporate Donors (Partners): Our Partners may have access to Personal Data for the purposes described above. Namely, our Partners may have access to your Personal Data for the purposes of (a) receiving metrics and analytics associated with a campaign that a Partner is supporting, (b) for providing Partners with your Personal Data to contact you about their products, services, and calls to action, and (c) for our Partners to use your Personal Data for their own marketing and promotional purposes. As such, we may share your Personal Data with our Partners who support campaigns on the Service or who benefit from campaigns on the Service.

5. STORING YOUR PERSONAL DATA

Your Personal Data will be kept only for as long as is necessary to fulfill the purposes set out in this policy. However, if required by applicable law or any regulatory obligation, we may retain your Personal Data for such period pursuant to such law or regulation. To effectively provide the Service, we may store non-Personal Data perpetually and may anonymize your Personal Data and store that anonymized information perpetually.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements.

6. SECURITY OF YOUR PERSONAL DATA

The security of your information is of paramount importance to us. We use reasonable efforts in keeping your Personal Data secure and in preventing any loss, unauthorized access or unlawful use of the information. 

Your SocialWalk account information is protected by a password for your privacy and security. In addition, we follow generally accepted industry standards to protect the personal information of our users, both during transmission and after we receive it. SocialWalk strives to use commercially acceptable means to protect your Personal Data, including use of encryption and secure hosting provided by industry leading third party vendors, firewalls, and hashing on select types of information collected by SocialWalk.

Only employees who need Personal Data to perform a specific job (for example, a customer service representative) are granted access to it. All of our employees are kept up to date on our privacy and security practices.

7. YOUR CHOICES AND RIGHTS

If you would like us to delete Personal Data, please contact us at support@socialwalk.us and we will respond within a reasonable time. Please note that some or all of the Personal Data may be required in order for the App to function properly, and we may be required to retain certain information by law. We offer you choices regarding the collection, use, and sharing of your Personal Data.

We note throughout SocialWalk Privacy Policy that we make available to our users the choice to readily opt out of providing information that they do not wish to share. You may opt out of providing information to SocialWalk by contacting support@socialwalk.us. 

We will periodically send you commercial emails that promote the use of our App. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the choice to opt out by following the unsubscribe instructions contained within the email or by contacting us directly. Unsubscribe instructions will be included in every email.

Despite your indicated email preferences, we may send you service related communication, including notices of any updates to SocialWalk Privacy Policy.

You may delete your account and any Personal Data we hold on you. You can exercise your right to delete your SocialWalk account and the personal information attached to it yourself, by triggering an account deletion via the Account section within the SocialWalk App. Open SocialWalk App -> Your Account Screen -> Settings Menu [top left corner] -> Delete Account.

Please note that we may be required to keep this information and not delete it (or to keep this information for a certain period, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our and or service provider archives. 

Please note that the above rights are not absolute and we may be entitled to deny user requests, wholly or partly, where exceptions under applicable law may apply.

8. THIRD PARTY SERVICES AND DATA COLLECTION

Our Service utilizes numerous third party services as part of the functionality of the Service. We may share your Personal Data with third parties as explained in this Privacy Policy. We have no control over such third parties or service providers. We encourage you to review the privacy practices of such third parties or service providers. We make no guarantees about, and assume no responsibility for, the information, services, or data/privacy practices of third parties or service providers.

Our Service may contain features or links to websites and services provided by third parties. Any information you provide via third party websites or services is provided directly to the operators of such websites or services and is subject to those operators’ policies governing privacy and security, even if accessed via the SocialWalk App or SocialWalk Website. We are not responsible for the content or privacy and security practices and policies of third parties to which links or access are provided through the SocialWalk App or SocialWalk Website. We encourage you to learn about third parties’ privacy and security policies prior to providing them with your personal information.

9. CHANGES TO SOCIALWALK PRIVACY POLICY

SocialWalk reserves the right to change this Privacy Policy at any time at its sole discretion. Any such changes shall take effect immediately when posted on the SocialWalk App and SocialWalk Website, and/or may be emailed to you. Your continued use of SocialWalk App following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. Information may be changed or updated without notice. Please check the Privacy Policy available on the SocialWalk App and SocialWalk Website regularly for any changes. 

Please note that at all times you are responsible for updating your Personal Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, changes will nonetheless be effective. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. 

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

10. CONTACT US

If you have any questions, comments and requests regarding this Privacy Policy or our Service or if you wish to change or delete your Personal Data, please feel free to contact us by email at support@socialwalk.us with subject line “privacy policy enquiry”.