Privacy Policy

Last Updated: April 11, 2026

Note: This privacy policy has been drafted to comprehensively reflect how the WalkTalk application collects and processes data. We recommend consulting with a qualified attorney for jurisdiction-specific compliance review before relying on this document for legal purposes.

WalkTalk ("we," "our," or "us") is operated by an individual developer based in the European Union. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and safeguard your information when you use the WalkTalk mobile application ("App"), available at the App Store.

By downloading, accessing, or using WalkTalk, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the App.

1. Information We Collect

1.1 Account Information

When you create an account, we collect:

1.2 Profile Information

You may optionally provide:

1.3 Activity and Social Data

1.4 Automatically Collected Data

Location Data

Health and Fitness Data

Camera and AR Data

Contacts

Device and Technical Data

1.5 Payment Information

Auto-Renewable Subscription Terms

  • Payment will be charged to your Apple ID account at the confirmation of purchase
  • Subscriptions automatically renew unless cancelled at least 24 hours before the end of the current billing period
  • Your account will be charged for renewal within 24 hours prior to the end of the current period at the then-current subscription price
  • You can manage and cancel your subscriptions by going to your device Settings → Apple ID → Subscriptions
  • Any unused portion of a free trial period, if offered, will be forfeited when you purchase a subscription
  • Subscription prices may vary by region and are determined by Apple's price tier system

2. How We Use Your Information

2.1 Providing and Operating the Service

2.2 Gamification and Social Features

2.3 Safety and Content Moderation

2.4 Improving the Service

2.5 Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we process your personal data on the following legal bases:

Purpose Legal Basis
Account creation, messaging, activities Performance of contract (Article 6(1)(b) GDPR)
Processing payments Performance of contract (Article 6(1)(b) GDPR)
Location sharing during activities Consent (Article 6(1)(a) GDPR), withdrawable via iOS Settings
Health/fitness data (pedometer) Explicit consent (Article 9(2)(a) GDPR)
Camera/AR access Consent (Article 6(1)(a) GDPR)
Push notifications Consent (Article 6(1)(a) GDPR)
Content moderation and safety Legitimate interest (Article 6(1)(f) GDPR) — user safety
Analytics and service improvement Legitimate interest (Article 6(1)(f) GDPR) — improving service quality
Compliance with legal obligations Legal obligation (Article 6(1)(c) GDPR)

3. AI and Automated Processing

3.1 AI-Powered Bot Users

Important Disclosure: WalkTalk includes AI-powered bot users ("Ghost Host" bots and "Agent" bots) that may create activities and interact with you in chat. These bots are designed to enrich the community experience. Bot interactions are powered by Google Gemini AI. Bot users have profile information and participate in activities similarly to human users.

3.2 AI-Generated Content

3.3 Automated Content Moderation

We use automated systems to review content for safety:

3.4 Natural Language Analysis

On iOS 17+, the App uses Apple's on-device Natural Language framework (NLLanguageRecognizer, NLTagger) to detect message language, classify intent (question, greeting, etc.), and assess sentiment. This analysis occurs entirely on-device and is not transmitted to any server.

3.5 On-Device AI Processing

Certain AI features on iOS 26+ use Apple Foundation Models that run entirely on your device. Data processed by these models (suggested replies, smart compose, language analysis) never leaves your device unless you choose to send a suggested reply as a message.

4. Location Data

How We Use Location

Important: Your real-time location is only visible to participants of activities you have actively joined. It is not shared with all WalkTalk users. When you leave an activity or the activity ends, real-time location sharing stops.

Location Data Storage and Retention

Privacy Controls

5. Information Sharing

5.1 With Other WalkTalk Users

5.2 Service Providers

We share data with the following third-party service providers who process data on our behalf:

Provider Purpose Data Shared
Firebase / Google Cloud Authentication, database, storage, cloud functions, push notifications, crashlytics Account data, messages, activity data, FCM tokens, location data, crash logs
Mapbox Maps, directions, map matching, geocoding, search, AR POI discovery GPS coordinates, route waypoints, search queries
Google AI (Gemini) Bot conversations, suggested replies, activity summaries Message context, activity data, user communication patterns
OpenAI (Moderation API) Text content moderation (toxicity, harassment, hate speech detection) Message text, activity descriptions, profile bios (text content only — no user identifiers sent to OpenAI)
Google Cloud Vision Image content moderation (SafeSearch) Uploaded chat images
Google Places API Checkpoint route generation (points of interest) Location coordinates, search radius, POI categories
Apple (WeatherKit) Weather data for activity creation and home display GPS coordinates
OpenWeatherMap Weather context for chat features GPS coordinates (rounded to 2 decimal places)
Apple (StoreKit 2) In-app purchases and subscription management Transaction data, Apple ID account token
Wikipedia API AR POI descriptions and thumbnails GPS coordinates, page IDs

5.3 Legal Requirements

We may disclose your information if required to do so by law, or in the good-faith belief that such action is necessary to:

5.4 Business Transfers

If WalkTalk is involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. We will notify you via the App or email before your data is transferred and becomes subject to a different privacy policy.

6. Data Retention and Deletion

6.1 General Retention

6.2 Chat Message Auto-Deletion

Chat messages are subject to automatic deletion based on the activity host's chat deletion preference:

When a chat room's scheduled deletion time is reached, all messages in that chat room are permanently deleted.

6.3 Location Data Retention

6.4 Account Deletion

You may delete your account at any time through the App's Settings. Upon account deletion:

6.5 Data Export

You may request an export of your personal data through the App's Privacy Settings. The data export includes your profile, activities, chat rooms, invitations, challenges, buddies, badges, notifications, and leaderboard entries. Exports are rate-limited to one request per 48 hours. The export is provided as a downloadable JSON file with a 1-hour download link expiry. An audit trail of your export requests is maintained.

6.6 Selective Data Deletion

You may request deletion of specific personal data (bio, profile picture, activity history) through the App's Privacy Settings without deleting your entire account.

7. Your Rights

7.1 Rights Under GDPR (EEA, UK, Switzerland)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation:

To exercise these rights, contact us at technical_support@walktalk.me. We will respond within 30 days as required by GDPR.

You also have the right to lodge a complaint with your local data protection supervisory authority.

7.2 Rights Under CCPA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act:

To exercise these rights, contact us at technical_support@walktalk.me.

7.3 In-App Privacy Controls

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Despite these measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data. You are responsible for keeping your account credentials confidential and for the security of the device you use to access WalkTalk.

9. International Data Transfers

WalkTalk is operated from the European Union. Your data may be transferred to and processed in countries outside your country of residence, including the United States, where our service providers (Google/Firebase, Mapbox, OpenWeatherMap) maintain servers.

For transfers from the EEA/UK to countries without an adequacy decision, we rely on:

By using WalkTalk, you acknowledge that your data may be processed in jurisdictions with different data protection laws than your own.

10. Children's Privacy

Age Requirement: WalkTalk is intended for users who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18. If you are under 18, you may not use the App.

If we learn that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a person under 18, please contact us immediately at technical_support@walktalk.me.

11. Third-Party Services and Links

WalkTalk integrates with the following third-party services. Each has its own privacy policy governing how they handle your data:

We are not responsible for the privacy practices of third-party services. We encourage you to review their privacy policies.

12. Cookies and Tracking Technologies

WalkTalk is a native iOS application and does not use browser cookies. However:

We do not use third-party advertising trackers or sell your data to advertisers.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

Your continued use of WalkTalk after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

For GDPR-related inquiries, you may also contact us at the email address above. We will respond to data subject access requests within 30 days.

If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.


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