Privacy Policy

WELCOME TO WALK TODAY

Please read this Privacy Policy carefully in order to ensure that you fully understand how we collect, use and disclose the information you transmit when you interact with us, visit our website (www.walk.today), or use, download or access our application and websites (collectively the “Services”) in the walk.today domain. By using our Services, you agree to the terms and conditions set forth in this Privacy Policy.

This Privacy Policy is incorporated into, and is subject to, our Terms of Service. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in our Terms of Service.

What? – Collection of Your Information

We collect different types of information from or through the Services. The legal bases for our processing of “Personal Information” (i.e. information that personally identifies you or could be used to personally identify you) are primarily that the processing is necessary for providing the Services and that the processing is carried out in our legitimate interests, which are further explained in the “How we Use Your Information” section. We may also process Personal Information upon your consent, asking for it as appropriate.

What you send us

When you use the Services, you may provide and we may collect Personal Information which include (but is not limited to) the following categories of information:

  • Your language of correspondence as derived by your mobile OS language unless specified otherwise;
  • A nickname and postal/zip code when you first install our app;
  • Your walking activities, including distances and geographical location;
  • Push notifications to let you be aware of new activities, rewards earned, and other appropriate notifications in direct relationship with the use of the app;
  • Your last name, first name, email address and mailing address when you select an activity where the reward will be delivered through regular or electronic form or for voluntarily referring other users;
  • Your visitor profile on our website and blog such as IP address, web browser and the device that you use;
  • Your interactions with us, whether in-app, by email, phone, on our blog or on our social media platforms;
  • For platform customers: additional information in regard to the proper use of our Services such as last name, first name, username, business name, title/role, business email address, business phone number, business address.

What is sent to us through our Services

We may also collect the following information when you use our Services:

  • We collect information on the devices that you use to access our Services. This information includes such elements as your IP address, web browser and the device that you use, the webpage that linked you to our sites and the identifiers associated with your devices. If you have activated the location service parameters on your devices, these can also send us information respecting your geographical location;
  • We use “cookies” to collect information and to operate and improve our Services and advertising. A cookie is a small data file that we store on your electronic device. We may use “persistent cookies” to record your email and password for when you log on to our Services in the future. We may use “session identifier cookies” to activate certain features of the Services, to better understand and improve your interaction with the Services and to monitor the overall use made of and traffic generated by the Services (length of visits, number of users, etc.);
  • Most web browsers allow you to configure your options so as to refuse cookies or ask for your consent before cookies are accepted from the websites that you visit. However, if you do not accept cookies, you might not be able to use all of our Services’ features;
  • We can also combine information that we collect through our Services with information that we collect from other sources such as a customer reward program for in-app targeted offering of activities and rewards.

Why? – How we Use Your Information

We take steps designed to ensure that only those employees who need access to your Personal Information to fulfil their employment duties will have access to it.

We use the information that we collect in a variety of ways in providing the Services and operating our business, including:

  • To authenticate you when you log on to your account or the blog;
  • To provide you with relevant activities to choose from and record your steps towards your reward;
  • To access, store and analyze your Data so that you may enjoy our Services;
  • To activate certain features. For example, instant notifications, geo-location based activities, or map representation of stores around you;
  • To understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, feature, and functionality;
  • To follow up on any question and request for assistance or information;
  • To understand your needs and preferences, and to assess your level of satisfaction with our Services;
  • To send you bulletins on our products, services, news and events and to follow up on our offers, promotions or contests (for example, to send you your referral credits when you have referred someone to our Services), to the extent permitted by applicable law;
  • To comply with legal and regulatory requirements, where applicable.

To Whom? – Disclosure of Your Information

Rest assured: we do not sell or market your Personal Information to third parties. Your Data belongs to you. However, in certain circumstances, in order to perform the Services, we may disclose certain information that we collect from you:

  • Within our family of companies, including parents, corporate, affiliates, subsidiaries, business units and other companies that share common ownership;
  • To our service providers or partners, so that they can help us provide, improve and promote our Services, but only when they require such information to perform their services or carry out their mandate. We may provide Personal Information to our providers and partners to process it for us based on our instruction and in compliance with our privacy policy;
  • In the context of a business transaction relating to any reorganization, merger, sale of assets, funding or acquisition of all or part of our activities by another corporation, including in the context of a due diligence or closing process;
  • In all cases where such disclosure is permitted or required by applicable law (for example, court order, situation that threatens the life, health or safety of an individual).

When we disclose your Personal Information to third parties, we take reasonable measures to ensure that the rules set forth in this Privacy Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.
We may finally make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding your interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Services.

Your Options

We offer you a number of options. Here are a few:

  • You may be given the option to access or register for the Services through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Facebook account, or otherwise have the option to authorize an Integrated Service to provide Personal Information or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Privacy Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Services;
  • You can edit your contact information and language of communication at all times. This is the best way to ensure that your Personal Information is accurate and up to date;
  • You can change your password at all times;
  • You can subscribe and unsubscribe to our promotional offers;
  • You can log out of your account securely by clicking on the “Log Out” button;
  • You can delete your account at all times by contacting our customer support team.

Other Websites and Social Media

Our website and blog may contain links to other websites which are owned and operated by third parties, whether these be partners, suppliers or social media like Facebook, Twitter, Instagram, or others. We have no control over the operation of these sites or the use that you make thereof, and we are not responsible for any of their procedures and practices.

Some features, such as data sharing, offer you the possibility of granting third parties access to your information, for example through API interfaces. Remember, however, that the use these third parties make of your information will be governed by the privacy policies of those third parties.

Also bear in mind that anyone may read, collect and use information that you publish in a public forum such as our blog or on social media.

Referencing Campaigns

We may from time to time invite you to share a promotional offer or to refer the use of our Services to members of your family or close friends. In such cases, it is your responsibility to ensure that these individuals are indeed members of your family (spouse, common-law partner, parent or child) or are people with whom you have a personal relationship (frequent communications, shared affinities, opinions, etc.). In short, we would appreciate it if you only invited people who are part of your close circle and who are likely to be interested in our Services.

Retention and Conservation of Your Information

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Service, you consent to the transfer of information to countries outside your country of residence, including the United States, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your Personal Information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of Personal Information from the EU/EEA to third country. Information can also be stored locally on the devices that you use to access our Services.

You Data is stored for as long as we need it to provide the Services to you, or as required by applicable laws, regulations, or government orders. If you delete your account, we will also delete this information. However, please note that: (1) there may be a delay before this information is deleted from our servers and our backup servers; and (2) our legal obligations might require us to retain this information. With the exception of paid accounts, we reserve the right to delete your account if you fail to access our Services for twelve (12) consecutive months. Before deleting your account, we will send you a notice at the email address associated with your account.

Children

Our Services are not intended for children under 13 years of age. If we learn that we have collected Personal Information on a child under 13 years of age without first having received the authorization of a parent or guardian, we will take the necessary measures to delete that information within a reasonable timeframe.

Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate physical, technical and administrative safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards. If you believe your Personal Information has been compromised, please contact us as set forth in the “Contact Information” section. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

Right to Access and Correct

On written request and subject to proof of identity, you may access the Personal Information that we have collected, used or disclosed and request that it be corrected, as authorized or required by applicable law.

Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your Personal Information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of Personal Information about you, under certain conditions; (v) the right to demand that we restrict processing of your Personal Information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your Personal Information is inaccurate; (vi) the right to data portability of personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at: http://ec.europa.eu/justice/data-protection/index_en.htm.

Update

Our Privacy Policy may be periodically amended to reflect changes made to our practices. If we make any such change, we will post a notice to that effect on our website in order to inform you of the date on which these amendments will come into effect. We therefore invite you to consult our website from time to time to stay informed of the latest developments. Continued use of our Services after the effective date will be construed as an acceptance of these changes on your part. The date of the last update is the one that appears at the bottom of the following page.

Contact Information

If you have any questions or comments about this Policy or your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer (or Data Protection Officer) can be reached by mail or email using the following contact information: info@walk.today