1.       GENERAL

Privacy and data protection are important to us at Walking Talking AB, reg. no 556787-5421 (“Walking Talking”, “we”, “us” or “our”). This Privacy Policy aims to explain how we process personal data as a personal data controller while providing the Service (as defined herein), and what rights you have as a data subject. Walking Talking’s processing of personal data is carried out in accordance with applicable legislation, including the general data protection regulation (“GDPR”). Set forth below is a description of how personal data are processed by us.

This Privacy Policy is incorporated in, and an integral part of our Terms. Terms defined in our Terms applies to this Privacy Policy unless otherwise stated herein.

The mobile app and webb-app (“The App”) gives you the opportunity to get in contact with other Users in order to do walk-n-talks together (the “Service”). This Privacy Policy applies to the personal data we collect and process in connection with your use of the Service, which for example, but not limited to, include registering for a personal User Account, send messages or communicate with other Users in the App, post or upload information in the App, etc.

If you have any further questions or queries concerning how we process your personal data, you are welcome to contact us at: kontakt@walkingtalking.com.

 

  1.       PERSONAL DATA WE PROCESS

Personal data refers to information which, directly or indirectly, may be associated with a living natural person such as a name, personal identity number, IP address, geographic position, photos, e-mail addresses, phone number, payment card details and other contact details and authentication methods etc. In addition to the above, Walking Talking also collects and process Your Content, which you as a User submits, publish, etc. within your User Account when using the App.

We process personal data about persons who:

2.2.1     are a User and uses the Service through Walking Talking’s App;

2.2.2     receives our newsletters, other communication and/or attend ours and our Users events;

2.2.3     are otherwise affected by the Service; or

2.2.4   are employed by, is an ambassador, student or applies for a job or to become an ambassador or trainer with Walking Talking.

We process personal data for the purposes of administering and performing the Service, analyse web traffic and keep track of User behaviour, enabling customer service, communicate with you, fulfilling our legal obligations, recruiting staff, marketing the Service and to use social features.

Personal data which is processed by Walking Talking is either directly provided by you, indirectly provided by you via your Facebook or Google account, Apple ID or e-mail address (subject to your selection) or automatically collected through your usage of the App and the Service. Some of the personal data you choose to provide us with may be considered as special categories of personal data and are subject to special security measures, according to GDPR. Special categories of personal data are for example, but not limited to, racial or ethnic origins, sexual orientation, political opinions and religious beliefs. By submitting special categories of personal data in the App via your User Account as Your Content, you thereby give us your consent to process such special categories of personal data.

You, as a User, are responsible for any personal data obtained, published or shared via the App which you have obtained from a third party. You shall also be able to confirm that you have such third party’s’ consent to provide such personal data to us.

Depending on the User’s device, the App may request certain permissions that allows the App to access the User’s personal data on such device. Permissions must always be granted by the User before respective information is accessed and processed by the App and includes, but is not limited to, camera permission, precise location permission (continuous) and reminders permission. In order to revoke these permissions, we refer you to your devices’ settings. Note that revoking of such permissions might impact the proper functioning of the App.

 

  1.       LEGAL BASIS

We process personal data when necessary to (i) provide our Service and fulfill our obligations towards you in accordance with the Terms and applicable legislation, (ii) communicate with you, (iii) send out newsletters to you, (iv) when we have your consent to process your personal data or (v) when there is another legitimate interest for us to process your personal data.

Your personal data will always be processed confidentially and protected by appropriate security measures in order to prevent unauthorized access, disclosure, modification or unauthorized destruction of your personal data. Walking Talking ensures that companies that process and/or manage personal data on our behalf, uses a high level of security measures in order to protect your personal data.

We may disclose your personal data to external parties with whom we collaborate e.g. marketing agencies, e-mail service providers, hosting providers, analyse system providers, etc. We may also disclose your personal data when we have a legal obligation to do so, e.g. due to anti-money laundering legislation, tax legislation, court orders or requests from government authorities, etc.

We may transfer and store personal data in countries outside the EU/EEA in order to perform the Service. When Walking Talking transfers personal data to such countries, we will ensure that your personal data is adequately protected through the use of relevant safeguards.

 

  1.       STORAGE AND DELETION OF PERSONAL DATA

Personal data will only be stored for as long as it is necessary in order for us to fulfil the purposes of the processing, or for as long as we are required to store the information according to applicable legislation and relevant guidelines. The personal data is thereafter erased in accordance with our erasure procedure.

You may unsubscribe from our newsletters or similar communication at any time. In such event we will no longer store or process your personal data for such purposes.

Processing of your personal data, which is based on your given consent may be stored and processed until you withdraw such given consent.

 

  1.       YOUR RIGHTS AS A DATA SUBJECT

Walking Talking is the data controller for the processing of your personal data, and as a data subject you have certain rights as regards to your personal data. The rights are however not absolute, meaning that there are exceptions to some of the rights where we cannot proceed and fulfill your request.

As a data subject, you have the following rights:

5.2.1     Right to withdraw your consent – meaning that you have the right to withdraw your consent where Walking Talking process your personal data based on consent;

5.2.2     Right to access – meaning that you have the right to request a confirmation of our processing of your personal data, to receive information about the processing, access the personal data in question, and the right to obtain a copy of your personal data;

5.2.3     Right to rectification – meaning that you have the right to have any incorrect personal data about you as a data subject corrected by us;

5.2.4     Right to erasure – meaning that you have the right to have your personal data erased under certain circumstances. This right is limited and we may be obligated to save your personal data in accordance with applicable law;

5.2.5     Right to object – meaning that you have the right to object to Walking Talking’s processing of your personal data under certain circumstances, such as direct marketing;

5.2.6     Right to restricted processing – meaning that you have the right to have Walking Talking restrict the processing of your personal data, but not delete it; and

5.2.7     Right to data portability – meaning that you may request Walking Talking to transfer your personal data to another data controller.

If you feel that our processing of your personal data does not comply with applicable data protection legislation, you are entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen).

Any requests by you as a data subject under this Privacy Policy shall be sent to: kontakt@walkingtalking.com. Requests will be handled as soon as possible, but no later than within three (3) months from the date which Walking Talking received the request.

 

  1.       LINKS TO THIRD PARTY SITES

Our Website and App may contain links to third party sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by Walking Talking and, therefore, we strongly advise you to review the privacy policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

 

  1.       ADS AND SPONSORED CONTENT

Walking Talking uses Your Content and your personal data in order to select and personalize the ads that we may show you in the App via your User Account. In order to protect your privacy and personal data in accordance with this Privacy Policy, we will always use anonymized data when we are in contact with marketing agencies etc.

 

  1.       COOKIES

Walking Talking uses cookies on Walking Talking’s Websites (www.walkingtalking.se,www.walkingtalkinginternational.com and trainingat.walkingtalkinginternational.com) for the purpose of providing and updating the Service and to improve the user experience and distinguish different users on Walking Talking’s platforms. For information on how Walking Talking uses cookies, we refer to our Cookie Policy, as amended from time to time, which is available on our Website (at: www.walkingtalking.se/cookie-policy).

 

  1.       AMENDMENTS AND ADDITIONS

Walking Talking has the right to amend this Privacy Policy from time to time without giving the User prior notice of such change. Should any change affect the processing of personal data, which is based on your consent, Walking Talking shall collect a new consent from you regarding such processing. The latest version of this Privacy Policy will always be available on Walking Talking’s Website and App, and we advise you to review this Privacy Policy periodically for any changes.

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