Terms of Service & Privacy Policy

Last Updated: February 2026

Part One — Terms of Service

1. Acceptance of Terms

By downloading, installing, or using Walktivate ("the App"), you confirm that you have read, understood, and agree to be bound by these Terms of Service. If you do not agree, please do not download or use the App.

Your consent to the collection and processing of personal data is obtained separately through in-app permission prompts — it is not implied by your acceptance of these Terms. Please refer to Part Two (Privacy Policy) for full details.

2. Description of the Service

Walktivate is a fitness step-tracking and social competition platform available on iOS. The App allows users to:

3. User Accounts

3.1 Account Creation

You must provide accurate, complete, and current information when registering. You are responsible for keeping your credentials confidential and for all activity under your account. Notify us immediately at support@walktivate.com if you suspect any unauthorised access.

3.2 Age Requirement

In accordance with Article 8 of the General Data Protection Regulation (GDPR) as implemented under Bulgarian law, you must be at least 14 years old to use Walktivate independently. Users between the ages of 14 and 18 may use the App but are encouraged to do so with parental awareness.

If we become aware that a user under 14 has created an account without verifiable parental consent, we will delete the account and all associated data without undue delay.

4. User Conduct

By using the App you agree NOT to:

5. Health and Fitness Disclaimer

Walktivate is not a medical device and is not intended to diagnose, treat, cure, or prevent any disease or medical condition. The App provides general fitness tracking only and must not be used as a substitute for professional medical advice, diagnosis, or treatment. Always consult your healthcare provider before starting any new fitness programme.

6. Apple Health Integration

The App requests permission to read step count and walking distance from Apple Health. This permission is requested separately via your device's native permission prompt and requires your active approval. You may revoke this permission at any time through your iPhone's Settings. We never write to, modify, or delete any data in Apple Health.

7. Location Access

The App requests access to your approximate location (city and country only) for the purpose of placing you in the correct regional leaderboard. Location access is requested via your device's native permission prompt with the following options only: Allow Once, Allow While Using the App, or Don't Allow. We do not offer or use continuous background location tracking.

Denying location permission does not prevent you from using the App's core features; the App will simply default to the location set for your account, if there is one. Otherwise, you will not appear on any city or country leaderboards.

8. Advertising

The App displays advertisements from Google AdMob. We do not control the content of third-party advertisements. Cookie and tracking consent for advertising purposes is requested separately via a dedicated consent prompt upon first launch, in compliance with EU ePrivacy rules. You may accept or decline personalised advertising independently of your use of the App's core features.

We do not share personally identifiable information (such as your name or email address) with advertisers.

9. Intellectual Property

All content, features, and functionality of Walktivate — including text, graphics, logos, and software — are owned by Walktivate and are protected by applicable copyright, trademark, and intellectual property laws. You may not copy, modify, reproduce, upload, post, distribute, or create any documents and/or information from or related to Walktivate without our express written permission.

10. User-Generated Content

You retain ownership of any content you submit to the App (such as challenge names or profile information). By submitting content, you grant Walktivate a worldwide, non-exclusive, royalty-free licence to use, display, and distribute that content solely within the App's features (e.g. leaderboards, challenges). You are solely responsible for ensuring that any content you submit does not violate applicable laws or third-party rights.

11. Account Termination and Data Deletion

By You: You may delete your account at any time through the App's Privacy Settings. Upon deletion, all personal data associated with your account — including challenges you have created, friendships, and activity history — will be permanently and irreversibly deleted from our systems within 30 days, in accordance with GDPR requirements.

By Us: We reserve the right to suspend or terminate your account if you violate these Terms or engage in conduct harmful to other users or the App. Where feasible, we will notify you before taking such action.

12. Disclaimers and Limitation of Liability

As-Is Basis: The App is provided "as is" and "as available" without warranties of any kind, express or implied. We do not guarantee that the App will be error-free, secure, or uninterrupted.

Limitation of Liability: To the fullest extent permitted by Bulgarian and EU law, Walktivate shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of the App, including but not limited to data loss, loss of profits, or personal injury resulting from fitness activities.

Nothing in these Terms limits liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation, to the extent such limitation is prohibited by applicable law.

13. Indemnification

You agree to indemnify and hold harmless Walktivate and its affiliates from any claims, damages, losses, or expenses (including reasonable legal fees) arising from: (a) your use of the App; (b) your violation of these Terms; or (c) your violation of any third-party rights.

14. Changes to These Terms

We may update these Terms from time to time. We will notify you of significant changes by posting a notice within the App or via email to your registered address. Your continued use of the App after the effective date of changes constitutes your acceptance of the updated Terms. If you do not agree to the updated Terms, you must stop using the App and may delete your account.

15. Governing Law and Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the Republic of Bulgaria and applicable European Union law. Any disputes arising out of or in connection with these Terms or your use of the App shall be submitted to the exclusive jurisdiction of the competent courts of Bulgaria.

Nothing in this clause affects your rights as a consumer under mandatory Bulgarian or EU consumer protection law.

Part Two — Privacy Policy

1. Introduction and Controller Identity

Walktivate ("we," "our," or "us") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have.

Data Controller: Walktivate
Contact: support@walktivate.com
Country of establishment: Republic of Bulgaria

This policy is issued in compliance with:

If you have any questions about how we handle your data, please contact us at support@walktivate.com.

2. What Data We Collect and Why

2.1 Account Information

DataPurposeLegal Basis
Full nameAccount identificationArt. 6(1)(b) GDPR — contract performance
Email addressAccount login, notificationsArt. 6(1)(b) GDPR — contract performance
UsernamePublic display on leaderboardsArt. 6(1)(b) GDPR — contract performance
Password (bcrypt hash — never plain text)Account securityArt. 6(1)(b) GDPR — contract performance

2.2 Location Data

DataPurposeLegal Basis
City and country (derived from GPS at moment of request, or manually set)Regional leaderboard placementArt. 6(1)(a) GDPR — consent

Important: We never store GPS coordinates, precise location, movement history, or real-time position. Only the city and country strings are saved. If you deny location permission, a default location may be used if you have set one manually in your profile.

Your city is visible only to your accepted friends. It is not displayed publicly, though users may infer general location from leaderboard rankings.

2.3 Health Data — Special Category (Article 9 GDPR)

DataPurposeLegal Basis
Step count (read from Apple Health)Activity tracking, leaderboards, challengesArt. 9(2)(a) GDPR — explicit consent
Walking/running distance (read from Apple Health)Activity tracking, leaderboards, challengesArt. 9(2)(a) GDPR — explicit consent

⚠️ Step count and walking distance constitute health data under Article 9(1) GDPR and are therefore special category data subject to heightened protection. We process this data only on the basis of your explicit, separate consent, obtained through Apple's native HealthKit permission prompt. You may revoke this consent at any time through iPhone Settings > Privacy & Security > Health > Walktivate.

We never write to, modify, or delete data in Apple Health. We never share your health data with advertisers or any third party, except as strictly required by law.

2.4 Social and Activity Data

DataPurposeLegal Basis
Friend connectionsSocial features, challenge participationArt. 6(1)(b) GDPR — contract performance
Challenge participation and resultsLeaderboards, badgesArt. 6(1)(b) GDPR — contract performance
Achievement badgesUser progress displayArt. 6(1)(b) GDPR — contract performance

2.5 Technical and Usage Data

DataPurposeLegal Basis
Device type, OS version, app versionBug fixing, compatibilityArt. 6(1)(f) GDPR — legitimate interests
Session logs, error logsSecurity, stabilityArt. 6(1)(f) GDPR — legitimate interests
IP address (temporary)Security, fraud preventionArt. 6(1)(f) GDPR — legitimate interests

We do not use technical data to build advertising profiles or to make automated decisions with legal or significant effects on you.

2.6 Advertising Data (Google AdMob)

DataPurposeLegal Basis
Cookie/device identifiers (if consent given)Personalised advertisingArt. 6(1)(a) GDPR — consent
Non-personalised ad serving (if consent declined)Non-targeted advertisingArt. 6(1)(f) GDPR — legitimate interests

Consent for advertising cookies is requested via a dedicated opt-in prompt on first launch. You may withdraw this consent at any time through Settings > Privacy within the App.

3. What We Do NOT Collect

To be fully transparent, Walktivate does not collect:

4. How Your Data is Shared

4.1 Visible to Other Users

DataWho Can See It
UsernameAll users (leaderboards, challenges)
Step count / leaderboard rankingAll users on relevant leaderboard
CityAccepted friends and all users on city leaderboard (by participation)
CountryAll users on country leaderboard (by participation)
Full nameNo one (not publicly visible)
Email addressNo one (not publicly visible)

Note on leaderboards: A user appearing on a city leaderboard does not explicitly display their city to other users unless they are friends. However, users may be able to infer approximate location from leaderboard participation. No precise location is ever displayed or stored.

4.2 Third-Party Service Providers

We share data with the following categories of processors, bound by data processing agreements:

We do NOT sell your personal data to any third party.

4.3 Legal Disclosure

We may disclose your data to competent authorities if required by Bulgarian or EU law, court order, or to protect the rights, safety, or property of Walktivate or its users.

5. Legal Bases for Processing — Summary

All processing of your personal data is based on one of the following legal bases under the GDPR:

Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms. You have the right to object to such processing at any time (see Section 7).

6. Data Retention

Data TypeRetention Period
Account data (name, email, username)Until account deletion, then deleted within 30 days
Health data (steps, distance)Until account deletion, then deleted within 30 days
Location data (city, country)Until account deletion, then deleted within 30 days
Challenge and social dataUntil account deletion, then deleted within 30 days
Technical logs (IP, error logs)Maximum 90 days from collection
Advertising consent recordsUntil consent is withdrawn or account deleted

When you delete your account through the App's Privacy Settings, all data associated with your account is permanently deleted within 30 days, including challenges you have created. Certain anonymised, non-identifiable aggregate statistics (e.g. total app users) may be retained for analytical purposes but cannot be linked back to you.

We may retain data beyond these periods only where required by a specific legal obligation under Bulgarian or EU law.

7. Your Rights Under GDPR

Under the GDPR, you have the following rights, which you may exercise free of charge:

RightWhat It MeansHow to Exercise
Access (Art. 15)Obtain a copy of all personal data we hold about youEmail support@walktivate.com
Rectification (Art. 16)Correct inaccurate or incomplete dataIn-app profile settings or email
Erasure (Art. 17)Delete your account and all associated dataIn-app Privacy Settings or email
Portability (Art. 20)Receive your data in a structured, machine-readable formatEmail support@walktivate.com
Restriction (Art. 18)Limit processing of your data in certain circumstancesEmail support@walktivate.com
Objection (Art. 21)Object to processing based on legitimate interestsEmail support@walktivate.com
Withdraw consentRevoke Apple Health access, location access, or ad consent at any timeDevice Settings or in-app Privacy Settings
Automated decision-making (Art. 22)Not to be subject to solely automated decisions with significant effectsNot applicable — we do not use such processing

We will respond to all requests within one month of receipt, as required by Article 12 GDPR. This period may be extended by a further two months for complex or numerous requests, in which case we will notify you.

8. International Data Transfers

Your data may be stored and processed on servers located outside the European Economic Area (EEA), including in the United States, through our hosting provider Railway and Google AdMob.

Such transfers are made in compliance with Chapter V of the GDPR using Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for your personal data. You may request a copy of the applicable transfer safeguards by contacting us at support@walktivate.com.

9. Data Security

We implement the following technical and organisational security measures, pursuant to Art. 32 of Regulation 2016/679:

No system is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Bulgarian Commission for Personal Data Protection (KZLD) within 72 hours and, where required, notify affected users without undue delay, in accordance with Articles 33 and 34 GDPR.

10. Cookies and Advertising

10.1 Cookie Consent

Upon first launch, the App displays a dedicated consent prompt (Google's EU consent framework) asking whether you agree to the use of cookies and similar tracking technologies for personalised advertising. This prompt requires active opt-in — no options are pre-selected. Declining does not affect your ability to use the App's core features.

You may withdraw or change your cookie consent at any time through Settings > Privacy within the App.

10.2 Google AdMob

We display advertisements through Google AdMob.

If you have given consent:

If you have declined consent:

We do not pass your name, email address, or health data to Google AdMob under any circumstances.

11. Children's Privacy

Walktivate is not directed at children under the age of 14. We do not knowingly collect personal data from children under 14. If you believe a child under 14 has registered an account, please contact us immediately at support@walktivate.com and we will delete the account and all associated data without undue delay.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of significant changes by posting a notice within the App or via email to your registered address at least 14 days before the changes take effect. Your continued use of the App after the effective date constitutes acceptance of the updated policy. If you do not agree, you may delete your account before the changes take effect.

13. Contact and Complaints

Data Controller Contact:
Name: Nikolay Varamezov
Address: Pliska 2b, Bankya 1320, Bulgaria
Email: support@walktivate.com

For any questions, data access requests, or concerns about how we handle your personal data, please contact us at the above address. We will respond within one month.

Right to Lodge a Complaint:

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Bulgarian supervisory authority:

Commission for Personal Data Protection (Комисия за защита на личните данни — КЗЛД)
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Website: www.cpdp.bg
Email: kzld@cpdp.bg

Walktivate is established in Bulgaria and our main establishment for the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR") is located at Pliska 2b, Bankya 1320, Bulgaria. Accordingly, the Bulgarian Commission for Personal Data Protection has primary jurisdiction over our cross-border data processing activities within the European Economic Area.

Notwithstanding the above, you retain the right to lodge a complaint with the data protection authority in the EU member state in which you reside, work, or in which the alleged infringement occurred. A list of EU data protection authorities and their contact details is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

You also have the right to seek a judicial remedy before the competent Bulgarian courts.

Contact Us

For any questions, data requests, or complaints regarding these Terms or our Privacy Policy:

Email: support@walktivate.com

You also have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (КЗЛД) if you believe your data rights have been violated.

© 2026 Walktivate. All rights reserved.