Privacy policy

Version: draft v4 of 16 October 2026. Status: not reviewed by a legal professional. The French version prevails in case of discrepancy, except where local mandatory law says otherwise.

Data controller: Dany [TO BE COMPLETED BY DANY: surname], sole trader, [TO BE COMPLETED BY DANY: address]. Personal data: privacy@walkwards.com. Help: support@walkwards.com. Data protection officer: [TO BE COMPLETED BY DANY: to be decided].

1. Data we process

Walkwards does not ask for your e-mail address. At sign-in, Apple or Google sends an e-mail address to our authentication provider (Supabase), which keeps it for sign-in only: we do not use it to write to you, for advertising or for gift cards. Walkwards uses no geolocation, does not read your contacts, collects no bank details and does not collect your calories.

The question "How did you hear about us?" is optional: your answer is only added to an anonymous counter, not linked to your account.

Your choice about personalised ads stays on your phone (Google consent screen): Walkwards keeps no copy.

Your phone's "physical activity" permission (walking, running, vehicle) is used against cheating; it is a phone permission that you can withdraw in its settings. [Data sent to the server: to be specified.]

2. Why and on what legal basis

• Providing the service (coins, missions, statuses, cards, nickname, country, goals): performance of the contract.
• Health data: explicit consent (GDPR Art. 9(2)(a)), which you can withdraw at any time in your phone settings and in the app. Your health data is not used for advertising or usage analytics, and is not sent to survey companies or ad networks. Without this consent the app stays usable (water, shop, profile), but your steps earn no coins, including steps taken during a period without consent.
• Proof of your consents, kept after account deletion (§5): obligation to be able to demonstrate consent (GDPR Art. 7(1)) and Walkwards' legitimate interest in case of a dispute. [Proposed legal basis, to be confirmed by a lawyer.]
• Proof of gift card requests and delivery in case of a dispute (§5): Walkwards' legitimate interest in being able to prove that a paid card was delivered and shown. [Proposed legal basis, to be confirmed by a lawyer.]
• Anti-cheat signals and score kept after account deletion (§5): legitimate interest in preventing fraud. If a new account is later created on the same installation of the app, the old account's signals (kept 12 months, without nickname or e-mail) may be linked to it, only for a human review before a gift card withdrawal; this link alone never blocks an account automatically and never removes coins. You can ask for a human check at support@walkwards.com. [Proposed legal basis, to be confirmed by a lawyer.]
• Blocking the phone of an account suspended for fraud (§5): when we suspend an account after a human review, the app installation linked to that account (a technical fingerprint, with no name or email) can no longer be used to sign up a new account; accounts already signed up on that phone keep working normally; the suspended account itself is stopped when it requests a gift card. The block is lifted with the suspension. If you think you are blocked by mistake (second-hand or borrowed phone), write to support@walkwards.com: a person checks and can lift the block. [Proposed legal basis: legitimate interest in preventing fraud, to be confirmed by a lawyer.]
• Welcome and referral bonuses: the same Apple or Google identity receives them only once, using a hashed fingerprint of that identity (legitimate interest in preventing fraud). [Proposed legal basis, to be confirmed by a lawyer.]
• Personalised advertising and tracking: consent (Google UMP consent screen in Europe, Apple's tracking permission on iPhone).
• Anonymised usage analytics: legitimate interest, without health data.
• Notifications: your device's permission.

3. Who receives your data

Processors and partners, under agreements and safeguards: Supabase (database and accounts, Paris); Cloudflare (network protection); Resend (technical messages); Sentry (technical errors); PostHog (usage, hosted in the EU, no health data); Apple and Google (sign-in, stores, notifications, integrity checks); Tremendous (gift cards: card chosen, amount and order reference; no e-mail or name [to be checked during the sandbox test]); ad networks AppLovin (MAX and Quality Service), InMobi, Google AdMob; survey partners CPX Research, TapResearch, BitLabs, TheoremReach, Pollfish, inBrain, Prime Surveys; game and offer partners Adjoe (Playtime), Tapjoy, Mychips, Tyrads; internal alert tools (UptimeRobot, Telegram, without full personal data); GitHub (code, no user data).

[Reserved line: new provider, with date added.]

Your gift card is shown in the app: the link or code is read again from Tremendous at each opening and is never stored by Walkwards.

Some survey and game partners are independent controllers for their own questionnaires and offers: their policies apply. Some game partners read the list of apps installed on your device, only with specific consent.

The list is kept up to date in the app. A new partner is added only with prior notice.

4. Transfers outside the European Union

Some providers (notably in the United States) may process data outside the EU. These transfers rely on standard contractual clauses or the EU-US Data Privacy Framework, and supplementary measures.

5. Retention

• Account: until deletion, then erased within 30 days; automatic deletion after 24 months of inactivity, with a notification 30 days before.
• Sign-in e-mail address and identity data (Apple or Google): erased with the account.
• Raw activity and health data: 14 months, then anonymous totals.
• Coin ledger: 18 months, then aggregated archive.
• Support requests: 3 years after closure.
• Archives kept after account deletion, apart from the active database, without your nickname or e-mail, looked at only by the publisher and only in case of a dispute or fraud:
  • gift card requests: 7 years [starting point to be specified];
  • gift card openings: 7 years from each time the card is opened in the app, then automatic deletion. Content: your account's technical identifier, the card request reference, the provider and its order reference, the card chosen and its amount, the date sent, the date of each opening and its result (card shown or unavailable). Never the card code, link or PIN;
  • proof of your consents (terms, age 16 and over, health consent): 7 years [starting point to be specified];
  • anti-cheat signals and score: 12 months [starting point to be specified];
  • phone block of a suspended account: as long as the suspension lasts, then 12 months after the suspended account is deleted (or 12 months after it is lifted).

  After your account is deleted, the technical identifier stays in these archives: it is pseudonymous data (it does not name you, but it could be linked back to you, for example if you write to support about a card). Example: you open your €10 card on 11 January, delete your account in February and write in March "I never saw my card": the archive lets us check.

6. Your rights

Access, rectification, erasure, restriction, objection, portability, withdrawal of consent, human review of any significant automated decision (account block): write to privacy@walkwards.com giving your nickname. You can also delete your account in the app's Settings (see Delete my account). No ID document is requested. [Procedure to verify who sent the request: to be defined.] Reply within one month. You may complain to the CNIL (France), the APD (Belgium) or your country's authority.

Your nickname and rewards country cannot be changed in the app; for inaccurate data, write to privacy@walkwards.com. [Scope of the right to rectification to be confirmed by a lawyer.]

Limit for the archives (§5): a request for erasure or an objection may not lead to their deletion before the end of their period, where keeping them remains necessary for the establishment, exercise or defence of legal claims (GDPR Art. 17(3)(e) for erasure; Art. 21(1) for objection). You keep your other rights over this data (access, restriction, complaint). [To be confirmed by a lawyer.]

7. Security

Encrypted communications; health data encrypted at rest; secrets stored server-side only; app integrity checks; administrator access limited, logged and protected by strong authentication; daily backups; in case of a breach, notification of authorities and affected people within legal deadlines (72 hours in the EU).

8. Minors

Walkwards is reserved for people aged 16 and over. If we learn that a user is younger, we close the account and delete their data. No ad is personalised for users under 18.

9. Cookies and trackers

The app uses no cookies. Advertising identifiers are used only with your consent, which you can change at any time in your phone settings.

10. Automated decisions

A risk score from 0 to 100 is calculated from security signals. It never removes coins already earned; it can delay a gift card request or put it under review. Above 90 out of 100, the account may be suspended automatically; this automatic suspension is switched off by default at launch. You are told in the app and you can obtain human intervention, express your point of view and contest the decision by writing to support@walkwards.com (GDPR Art. 22(3)). [Applicable exception (Art. 22(2)) and safeguards to be confirmed by a lawyer.]

11. Changes

This policy may change. Important changes are notified in the app before taking effect.