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DRAFT — pending legal review. This is a working template for WalkCoins's public legal surface. Before launch it must be finalised by Indian counsel covering the Online Gaming Act 2025, RBI PPI rules, the DPDP Act 2023, and applicable tax law. Placeholders in [brackets] need real company details.

Privacy Policy

Last updated: [date] · Governed by the DPDP Act, 2023

This Privacy Policy explains how [WalkCoins Company Pvt. Ltd.] ("WalkCoins", "we") collects, uses, shares, and protects your personal data when you use the WalkCoins mobile app and website. We process personal data as a Data Fiduciary under India's Digital Personal Data Protection Act, 2023 ("DPDP Act").

1. The one thing to know first

Your step and activity data is used only to award you coins. It is never used for advertising, ad targeting, or profiling, and is never sold or shared with data brokers. We maintain a strict technical separation (a "firewall") between the systems that read your step data and the systems that serve ads. This is a design commitment and, for HealthKit / Health Connect data, a platform policy requirement.

2. Data we collect

  • Account data: your mobile number (verified by OTP), and a device identifier used for security and one-account-per-device enforcement.
  • Activity data:step counts and related motion/activity data read from your device's motion sensor, Apple HealthKit (iOS), or Health Connect (Android), strictly to calculate coins and to detect fraud.
  • Rewards data: your coin ledger, redemptions, and the details needed to fulfil a reward (e.g. the mobile number you choose to recharge).
  • Device & integrity data: device model, OS version, and attestation signals (Google Play Integrity / Apple App Attest) used solely to prevent fraud and abuse.
  • Usage & diagnostics: app events and crash logs to keep the app working and to improve it.

3. How we use your data

  • To count your steps and credit coins at the published rate.
  • To operate rewards, redemptions, streaks, and leagues.
  • To detect and prevent fraud, spoofed steps, and abuse.
  • To provide support and respond to grievances.
  • To comply with legal obligations.

We do not use your health/activity data to serve or target advertising, and we do not perform behavioural profiling for advertising.

4. Consent

We collect and process your personal data based on your free, specific, informed, and unambiguous consent, obtained at sign-up and when you grant motion/health permissions. You may withdraw consent at any time in the app; withdrawing certain consents (like activity access) may stop coin earning.

5. Sharing

We share the minimum necessary data with:

  • Licensed rewards partners to fulfil the specific reward you redeem (e.g. a recharge or voucher aggregator).
  • Infrastructure and analytics processors (e.g. cloud hosting, crash reporting) bound by data-processing terms.
  • Authorities where required by law.

We never sell your personal data.

6. Age & children

WalkCoins is intended only for users aged 18 and above. We do not knowingly onboard anyone under 18, and we do not perform behavioural tracking or targeted advertising to minors. If we learn an account belongs to a minor, we will disable it.

7. Retention

We keep your data only as long as needed to provide the service and meet legal requirements, after which it is deleted or anonymised. You can delete your account and data at any time (see Data Deletion).

8. Your rights

Under the DPDP Act you may request access, correction, and erasure of your personal data, nominate a representative, and lodge a grievance. Exercise these in-app or via our Grievance Officer (see Contact).

9. Security

We use encryption in transit and at rest, access controls, and device attestation. No system is perfectly secure, but we take reasonable safeguards appropriate to the sensitivity of the data.

10. Changes

We will notify you of material changes to this policy in-app and update the date above.

11. Contact

Questions? Email aos.apps@brandmongo.com or reach our Grievance Officer via the Contact page.