walknow

1. Preamble, Purpose, Scope, and Legal Foundation

1.1. Introduction and Mandate

This comprehensive and legally binding Privacy Policy (“Policy”) meticulously delineates the principles, procedures, safeguards, and obligations governing the collection, processing, storage, transfer, disclosure, retention, and deletion of personal data by Walk Now (“Company,” “we,” “us,” or “our”) in connection with the Walk Now mobile application (“App”).

This Policy is crafted to ensure strict adherence to all applicable data protection laws, regulations, and international standards, including but not limited to the data protection regime of the Arab Republic of Egypt, and to provide users (“you” or “users”) with a transparent, exhaustive, and legally robust understanding of our data handling practices.

1.2. Territorial Scope and Applicability

This Policy applies to all users of the App, irrespective of geographical location, nationality, or domicile. The Company extends its data protection standards beyond national borders to ensure global compliance.

1.3. Binding Consent, Agreement, and Acknowledgement

By downloading, installing, accessing, or using the App, you unequivocally, irrevocably, and knowingly acknowledge, consent to, and agree to the terms and provisions of this Policy. If you do not agree, you must immediately and permanently cease use, uninstall the App, and refrain from any further interaction.

1.4. Legal Foundation and Compliance

This Policy is grounded in the principles of transparency, fairness, lawfulness, and data minimization, in compliance with applicable data protection laws. The Company is committed to ongoing compliance and regularly reviews its practices to align with evolving legal standards.

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2. Definitions, Interpretations, and Terminologies

2.1. Personal Data/Information

Information relating to an identified or identifiable natural person, including but not limited to:

• Names

• Email addresses

• Phone numbers

• Usernames

• Profile pictures

• Device identifiers

• Network information

Includes data that can indirectly identify a user when combined with other data.

2.2. Special Categories of Personal Data/Sensitive Data

Excluded from collection unless specifically consented to:

• Health data

• Genetic and biometric information

• Racial or ethnic origin

• Political opinions

• Religious/philosophical beliefs

• Trade union membership

2.3. Usage Data/Activity Logs/Behavioral Data

Automatically collected data from user interaction with the App, such as:

• Step count data

• In-app activities (e.g., spin and win, ads, transactions)

• Wallet and point transactions

• Session duration and clickstream behavior

2.4. Device Data/Information/Technical Data

Includes:

• Device type and OS version

• Unique device identifiers (IMEI, MAC address)

• IP address and network provider

• Screen resolution and language

2.5. Third-Party Services/Processors/Sub-Processors

External services that process data on behalf of the Company, including:

• Advertising (e.g., Google AdMob)

• Payments (e.g., Instapay, Vodafone Cash)

• Cloud & Analytics (e.g., AWS, Google Cloud, Firebase)

2.6. Data Controller/Processor Relationship/Joint Controllership

• The Company acts as Data Controller

• Third parties may act as Processors or Joint Controllers, depending on the context

2.7. Data Subject Rights/Individual Rights

Users have rights under data protection law:

• Access

• Rectification

• Erasure

• Restriction

• Portability

• Objection

• Freedom from automated decision-making

2.8. Data Security Breach/Personal Data Breach

A security breach that leads to accidental or unlawful destruction, loss, or unauthorized access to personal data.

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3. Data Collection, Processing, Minimization, and Purpose Limitation

3.1. Collection of Personal Data

User-Provided Information
Collected when users:

• Create accounts

• Update profiles

• Participate in app activities

• Communicate via support

Password Security
Passwords are encrypted using cryptographic techniques, such as salted hashes and adaptive key derivation.

Profile Pictures/User-Generated Content
Optional user submissions are stored and processed securely.

3.2. Collection of Usage Data

Step Count Data
Collected via device sensors for tracking and reward calculation.

In-App Activity Logs
Used for:

• Analytics

• Service improvement

• Security

• Fraud prevention

Transaction Records
Collected for:

• Accounting

• Auditing

• Regulatory compliance

3.3. Collection of Device Data

Device Identification
Used for:

• App performance optimization

• Security

• Compatibility checks

Advertising Identifiers
Used for targeted advertising (with user consent), via networks like Google AdMob.

Network Information
Used for security and performance tuning.

3.4. Collection of Advertising Data

Behavioral Targeting
Ad data collected by third-party SDKs like AdMob in accordance with their privacy standards.

3.5. Exclusion of Location Data

Zero-Location Policy

• No location data is collected, stored, or processed.

• Enforced via monitoring, audits, and sensor restrictions.

• Third-party SDKs are reviewed to ensure compliance.

3.6. Data Minimization & Purpose Limitation

Necessity & Proportionality
Only data strictly necessary for stated purposes is collected.

Data Retention
Personal data is retained only as long as necessary for its intended purpose.

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4. Legal Basis for Data Processing

4.1. Consent

Freely Given, Informed, and Unambiguous

• Collected via opt-in tools

• Users can withdraw consent anytime

4.2. Contractual Necessity

Processing is necessary for:

• Step tracking

• Reward redemption

• Account services

4.3. Legal Obligations

Data may be processed to comply with legal duties and government regulations.