App privacy policy (see below for Website privacy policy)

Information we collect

When you use our Services, we collect the following types of information.

Information you provide us

Account information

Some information is required to create an account on our Services, such as your name, email address, password, date of birth, gender, height, weight, and in some cases your mobile telephone number. This is the only information you have to provide to create an account with us. You may also choose to provide other types of information, such as a profile photo, biography, country information, and community username. 

Additional information

To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, like your logs for weight, sleep, or mood; an alarm; and messages on discussion boards or to your friends on the Services.

You may also connect with friends on the Services or invite friends who have not yet joined by providing their email addresses, accessing social networking accounts, or using the contact list on your mobile device. 

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message or other questionnaire input.

Payment and card information

Some devices may support payments and transactions via third parties. If you activate this feature, you must provide certain information for identification and verification, such as your name, credit, debit or other card number, card expiration date, and CVV code. This information is encrypted and sent to your card network, which upon approval sends back to your device a token, which is a set of random digits for engaging in transactions without exposing your card number. For your convenience, we store the last four digits of your card number and your card issuer’s name and contact information. You can remove the token from your account using your account settings. We do not store your transaction history.

If you purchase any item on our website, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. We do not store this payment information. We store your shipping address to fulfill your order. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.  

Coaching Services

Our coaching services are a platform for you to communicate with a health or wellness coach (“Coaching Services”). Coaches may be provided by third parties, as appropriate. If you use our Coaching Services, we collect information about such use, including the plan, goals, and actions you record with your coach, your calendar events, communications with your coach, notes your coach records about you, and other information submitted by you or your coach. 

Information we receive from your use on our services

Device information

Your device collects data to estimate a variety of metrics like the number of steps you take, the time you spend in different phases of walking, the characteristics of your gait, your distance traveled, weight, active minutes, falls and fall and ulceration risks. The data collected varies depending on which device you use. When your device syncs with our applications or software, data recorded on your device is transferred from your device to our servers.  

Usage information

When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you view or search content, install applications or software, create or log into your account, pair your device to your account, or open or interact with an application on your device. This may also include crash logs and the device ID, or other ID.

Background location service is used to get the app to connect and enable data collection, through connection to the insoles via Bluetooth Low Energy (BLE). This means that we ask you to not close the app between looking at it. Even when you don't actively look at it, if it is open in the background, it will be collecting data from the sensors in the insole.

Information we receive from third parties

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. You may also choose to grant us access to your exercise or activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.

We may partner with third parties that offer our Services to their customers and employees directly or through intermediary providers, such as clinics. In such cases, those third parties or the intermediary providers may supply us with your name, email address, or similar information (like a telephone number or subscriber ID) so that we can invite you to participate or determine your eligibility for particular benefits, such as discounts or free services. 

How we use information 

We use the information we collect for the following purposes. 

Provide and maintain the services 

Using the information we collect, we are able to deliver the Services to you and honor our Terms of Service contract with you. For example, we need to use your information to provide you, or your clinician, with a dashboard tracking your activity, foot and walking health, and other trends; to enable the community features of the Services; and to give you customer support.  

For the Services’ community features, we may use your information to help you find and connect with other users and to allow other users to find and connect with you. For example, your account contact information allows other users to add you as a friend.   

If you use the Coaching Services, we use your information to connect you with coaches, allow you to communicate with them through our Services, and help you achieve your goals to lead a healthier, more active life. For example, the goals that you provide allow you to develop a personal plan and set of actions in consultation with your coach.  

Improve, personalize and develop the services 

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.  

We also use your information to make inferences and show you more relevant content. Here are some examples: 

• Information like your height, weight, gender, and age allows us to improve the accuracy of your movement and activity statistics like the distance you traveled and the pressure exerted through your feet.
• We may personalize activity goals for you based on the goals you previously set and your historical movement or activity data. 

Communicate with you 

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the “Unsubscribe” link in an email.  

Promote safety and security 

We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.  

We use cookies and similar technologies for the purposes described above. For more information, please read our Cookie Use statement. 

How information is shared 

We never sell the personal information of our users. We do not share your personal information except in the limited circumstances described below. 

When you agree or direct us to share 

You may direct us to disclose your information to others, such as when you use our community features, and other social tools. For certain information, we provide you with privacy preferences in account settings and other tools to control how your information is visible to other users of the Services. Just remember that if you choose to participate in a challenge, information like your profile photo, total activity in the challenge, personal statistics, and achievements, is not governed by your privacy preferences and will be visible to all other challenge participants. 

You may also direct us to share your information in other ways, for example, when you give a third-party application access to your account, or give your clinician access to information. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications programs by emailing us at privacy@walkwithpath.com. 

For external processing  

We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys. 

For legal reasons or to prevent harm 

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person. 

Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person. 

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about foot health, exercise and activity, to partners under agreement with us, or as part of the community benchmarking information we provide to users of our Services. 

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity. 

Your rights to access and control your personal data 

We give you tools to access and control your personal data, as described below, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information, which your tools allow you to exercise, as outlined below. 

Accessing and Exporting Data: By logging into your account, you can access much of your personal information, including your dashboard with your movement, exercise, activity, and alerts statistics.  

Editing and Deleting Data: You can email us on privacy@walkwithpath.com to change and delete your personal information.  

If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by your device and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How Information Is Shared section. 

Objecting to Data Use: You can email us on privacy@walkwithpath.com to control your data use You can also use the application to unpair your device from your account at any time. 

Data retention 

We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. We keep other information, like your exercise or activity data, until you use your tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections. 

Analytics and advertising services provided by others  

We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications. To learn more about your privacy choices, please read our Cookie Use statement. 

Information security 

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. This includes two factor authentication. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact Customer Support. 

Our international operations and data transfers 

We operate internationally and transfer information to the United States and other countries for the purposes described in this policy. 

We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. 

Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an account, irrespective of which country you live in. For a list of the locations where we have offices, please see our company information at walkwithpath.com. If you later wish to withdraw your consent, you can delete your account as described in the Your Rights To Access and Control Your Personal Data section. 

Walk With Path Europe ApS remains responsible for personal information that we transfer to others who process it on our behalf as described in the How Information Is Shared section. If you have a complaint about our Privacy Shield compliance, please contact us. You may also refer a complaint to your local data protection authority, and in certain circumstances, invoke binding arbitration to resolve complaints not resolved by other means. 

European privacy disclosures 

If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”). 

Your data controller 

Walk With Path Europe ApS, a Danish company, is your data controller and provides the Services if you live in the EEA, UK, or Switzerland. For our contact information, please see walkwithpath.com. 

Health and other special categories of personal data  

To the extent that information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. You can contact us to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account. 

Our legal bases for processing personal data  

For personal data subject to the GDPR, we rely on several legal bases to process the data, including: 

• When you have given your consent, which you may withdraw at any time by contacting us at privacy@walkwithpath.com; 

• When the processing is necessary to perform a contract with you, like the Terms of Service; and
• Our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described in the How We Use Information section. 

How to exercise your legal rights 

Please review the Your Rights To Access and Control Your Personal Data section for how to exercise your rights under the GDPR to access and control your personal data. 

In addition to the various controls that we offer, in certain circumstances, you can seek to restrict our processing of your data, or object to our processing of your data based on our legitimate interests, including as described in the How We Use Information section. Under the GDPR, you have a general right to object to the use of your information for direct marketing purposes. Please see your notification settings to control our marketing communications to you about our products. Our Cookie Use statement describes your options for controlling how we and our partners use cookies and similar technologies for advertising. Please note that you can always delete your account at any time. 

If you need further assistance regarding your rights, please contact our Data Protection Officer at privacy@walkwithpath.com, and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority or with the Danish Data Protection Commission, our lead supervisory authority, whose contact information is available here.  

California privacy disclosures 

If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act ("CCPA"). 

How to exercise your legal rights 

You have the right to understand how we collect, use, and disclose your personal information, to access your information, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights. You may exercise these rights as described in the Your Rights To Access and Control Your Personal Data section, for example: 

By contacting us you may exercise your right to access your personal information, to understand how we collect, use, and disclose it, and to have it deleted.  

If you need further assistance regarding your rights, please contact our Data Protection Officer at privacy@walkwithpath.com, and we will consider your request in accordance with applicable laws. 

Categories of information we collect, use, and disclose for business purposes  

As described in the Information We Collect section, we collect the categories of personal information listed below. We receive this information from you, your device, your use of the Services, your coach if you use our Coaching Services, third parties (like the other services you have connected to your account, or third parties and intermediary providers if they offer you our Services as an employee or customer), and as otherwise described in this policy. We use and disclose these categories of information for the business purposes described in the How We Use Information and How Information Is Shared sections, respectively. The categories are: 

• Identifiers, like your name or username, email address, mailing address, phone number, IP address, account ID, device ID, cookie ID, and other similar identifiers.
• Demographic information, such as your gender, age, health information, and physical characteristics or description, which may be protected by law.
• Commercial information, including your payment information and records of the Services or devices you purchased, obtained, or considered (for example, if you added them to your shopping cart on the walkwithpath.com online store but did not purchase them).
• Biometric information, such as your exercise, activity, movement, or health data, including the number of steps you take, the time you spend in different phases of walking, the characteristics of your gait, distance traveled, weight, active minutes, falls and fall and ulceration risks, Coaching Services data, and any similar information to which you grant us access from another service.
• Internet or other electronic network activity information, such as the usage data we receive when you access or use our Services. This includes information about your interactions with the Services and about the devices and computers you use to access the Services.
• Electronic, visual, or similar information, such as your profile photo or other photos.
• Professional or employment related information, including any information (like your name, email address, or similar information) that your employer provides to us so that we can invite you to participate in or determine your eligibility for our Services that they offer to their employees.
• Other information that you provide, including account information such as your biography or country; information for features of the Services, for example, an alarm, information about your friends, and logs for weight, sleep or mood; Coaching Services data (provided by you or your coach); messages on the Services; and information recorded by your device which may vary depending on the device you use.
• Inferences drawn from any of the above, including the distance you traveled, sleep insights, and personalized exercise and activity goals. 

We never sell the personal information of our users. We do work with partners who provide us with advertising services as described in the Analytics and Advertising Services Provided By Others section. To learn more about how these partners collect data and your options for controlling the use of your information for interest-based advertising, please read our Cookie Use statement. 

Changes to this policy 

We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services. You can review previous versions of the policy in our archive. 

Who we are and how to contact us  

If you have questions about this policy, or need help exercising your privacy rights, please contact our Data Protection Officer at privacy@walkwithpath.com. 

You may also contact us at: 

Walk With Path Europe ApS

Attn: Legal Department (Privacy Policy)

Vesterbrogade 74, 2; 1620 Copenhagen, Denmark

 

 

Website privacy policy

This privacy policy sets out how Walk With Path Ltd. (“WWP”) uses and protects any information that you give when you use this website.

WWP is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

WWP may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 11th May 2018.

What we collect

We may collect the following information:

• Name
• Contact information including email address, phone number and postal address
• Demographic information such as postcode, preferences and interests
• Other information relevant to customer surveys and/or offers, and for use in scientific research.

How is the information collected

Information is collected in a variety of ways including online forms, opt in surveys (via email, phone and post) and statistical information gathered through cookies. No information is held longer than it is needed for the purpose it was given for.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping
• We may use the information to improve our products and services
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail, depending on preferences given. We may use the information to customise the website according to your interests
• We may contact you as part of ongoing scientific research if you have consented to this

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Any sensitive information given by those who opt in to take part in our ongoing scientific research will be kept pseudo-anonymised.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

• We will only contact you for marketing purposes if you have opted in. Otherwise we will only keep data recorded in forms for the intended purpose stated on the form.
• If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at info@walkwithpath.com or directly unsubscribing via links on our newsletters.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to info@walkwithpath.com.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

How to use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Klarna privacy notice

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.