Privacy Policy

1. Introduction

WalkTalk Creative Technologies Limited ("we," "us," or "our"), a company registered in England and Wales (company number 17246918) with its registered office at 590 Green Lanes, London, N13 5RY, United Kingdom, operates the WalkTalk mobile application (the "App") and the website at appwalktalk.com (the "Website"), collectively referred to as the "Service." We are the data controller for the personal information processed through the Service.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our Service. By using WalkTalk, you agree to the collection and use of information as described in this policy.

If you have questions about this policy, please contact us at officialwalktalk@gmail.com.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use certain features, you may provide:

• Account information: Email address, display name, profile bio, city
• Profile photo: Avatar image you upload
• Audio content: Voice recordings you create for routes and stops
• Photos: Images you upload for routes, stops, and notes
• Location data: Specific locations you choose when placing route stops on the map
• Notes: Text content you create within the app
• Creator accreditation data: If you apply to become an accredited creator, we collect your legal full name, date of birth, residential address, and the last 4 digits of a payment card for identity verification purposes

2.2 Information Collected Automatically

When you use the App, we automatically collect:

• Device information: Device model, operating system version, app version, unique device identifiers
• Usage analytics: Firebase Analytics events such as screens viewed, features used, and session duration
• Crash reports: Firebase Crashlytics data including stack traces, device state, and error logs to help us diagnose and fix issues
• Purchase records: Transaction IDs for in-app purchases (processed by Apple App Store or Google Play Store)

2.3 Location Data

WalkTalk uses your GPS location only when you are actively using a route or Free Walk mode. Location is used to:

• Trigger proximity-based audio playback when you approach a stop
• Display your position on the route map
• Calculate walking distance for WalkCoin rewards
• Discover nearby audio points in Free Walk mode

We do not collect your location in the background. Location tracking is active only while you are on the route player or Free Walk screen and stops when you leave those screens.

2.4 Camera & Microphone

The App requests access to your camera and microphone only when you explicitly choose to take a photo or record audio. We never access these sensors without your direct action.

2.5 Information from Third Parties

If you sign in using Google Sign-In, we receive your name, email address, and profile photo from Google, as permitted by your Google account settings.

3. How We Use Your Information

We use the information we collect to:

• Provide the Service: Create your account, display routes, play audio, enable route creation and publishing
• Process purchases: Verify and fulfill in-app purchases through Apple and Google payment systems
• Award coins: Calculate and distribute WalkCoins (based on walking distance) and TalkCoins (for creators whose content is listened to)
• Prevent fraud: Enforce anti-farming measures including a 24-hour cooldown on TalkCoin awards per listener per stop and a 2.2 m/s maximum speed gate on WalkCoin distance tracking
• Improve the Service: Analyze usage patterns via Firebase Analytics to understand which features are most valued
• Fix issues: Use crash reports from Crashlytics to diagnose and resolve bugs
• Verify creators: Process creator accreditation applications to ensure the quality and safety of published content
• Communicate: Send important service updates (e.g., policy changes, accreditation status)

4. Legal Bases for Processing (GDPR)

If you are in the European Economic Area (EEA), UK, or Switzerland, we process your personal data on the following legal bases:

5. Sharing Your Information

We share your information only in the following circumstances:

• Firebase / Google Cloud: Your data is stored and processed on Google Cloud infrastructure, which powers Firebase Authentication, Firestore, Cloud Storage, Analytics, and Crashlytics
• Apple & Google: In-app purchase transactions are processed by the Apple App Store and Google Play Store respectively
• Public profiles: Your display name, avatar, bio, and published routes are visible to other users of the App
• Legal requirements: We may disclose information if required by law, court order, or governmental authority

We do not sell your personal information. We do not share your data with third-party advertisers.

6. Data Storage & Security

Your data is stored on Google Cloud servers, primarily in the United States and European Union. We implement the following security measures:

• All data in transit is encrypted via HTTPS/TLS
• Firebase Security Rules restrict database and storage access based on authentication status and user roles
• Storage uploads require authenticated user metadata
• Creator accreditation data (personal identity information) is stored with restricted access controls

Local device storage: The App stores cached data locally on your device including:

• Image cache with a 30-day expiry (up to 500 objects)
• Local preferences via SharedPreferences
• Local data storage via Hive for offline functionality

7. Data Retention

8. Your Rights Under GDPR

If you are located in the EEA, UK, or Switzerland, you have the following rights:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Restriction: Request that we limit how we process your data
• Data portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw consent: Withdraw previously given consent at any time (e.g., location permissions via device settings)
• Complaint: Lodge a complaint with your local data protection authority. In the United Kingdom this is the Information Commissioner's Office (ICO) — ico.org.uk

To exercise these rights, contact us at officialwalktalk@gmail.com. We will respond within 30 days.

9. Your Rights Under CCPA

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

• Right to know: Request disclosure of the categories and specific pieces of personal information we have collected
• Right to delete: Request deletion of your personal information
• Right to opt-out of sale: We do not sell personal information, so this right is not applicable
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights

To exercise these rights, contact us at officialwalktalk@gmail.com.

10. Account Deletion

You can delete your account at any time through the App:

1. Open WalkTalk and go to Settings
2. Tap Delete Account
3. Confirm your decision

Upon deletion:

• Your profile, published routes, audio recordings, photos, and associated data will be queued for permanent deletion
• Deletion is processed within 30 days
• Some data may be retained longer if required by law (e.g., purchase transaction records for tax purposes)
• After deletion, your account transitions to an anonymous guest state

11. Children's Privacy

WalkTalk is intended only for adults aged 18 or older. It is not intended for anyone under the age of 18, and we do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from a person under 18, we will delete it.

If we become aware that we have collected personal data from a child under the applicable age limit, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at officialwalktalk@gmail.com.

12. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where Google Cloud infrastructure is located.

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

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Google's data processing terms and commitments under their Cloud Data Processing Addendum

13. In-App Purchases

All in-app purchases are processed by Apple (App Store) or Google (Play Store). We do not directly collect or store your full payment card details.

• Payment processing is handled entirely by Apple or Google
• We receive only a transaction ID and purchase verification token
• For creator accreditation, we collect only the last 4 digits of a payment card for identity verification — we never store full card numbers
• Refunds are handled by Apple or Google according to their respective refund policies

14. Cookies & Tracking Technologies

Website: The WalkTalk website (appwalktalk.com) does not use cookies or third-party tracking technologies.

Mobile App: The App uses the following tracking technologies:

• Firebase Analytics: Collects anonymized usage events and session data. You can opt out of analytics collection through your device settings (Limit Ad Tracking on iOS, Opt Out of Ads Personalization on Android)
• Firebase Crashlytics: Collects crash reports and diagnostic data automatically to help us identify and fix issues

We do not use third-party advertising trackers or retargeting technologies.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes:

• The "Last Updated" date at the top of this page will be revised
• For significant changes, we will notify you through the App
• Continued use of the Service after changes constitutes acceptance of the updated policy

We encourage you to review this page periodically for the latest information on our privacy practices.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you can reach us at:

• Privacy inquiries: officialwalktalk@gmail.com
• General support: officialwalktalk@gmail.com
• Postal address: WalkTalk Creative Technologies Limited, 590 Green Lanes, London, N13 5RY, United Kingdom

We aim to respond to all inquiries within 30 days.