This policy explains how Walk Or Lose ("Walk Or Lose", "we", "us") handles your information when you use the Walk Or Lose app, website, or services. If you don't agree with it, don't use the service — and feel free to write us and tell us why.
Short version
We collect what we need to run a step program with a real money pledge attached — your account info, your step counts, your payment method, and basic device data. We do not sell your data. We share with payment, identity-verification, and fraud-detection vendors who are contractually limited to processing it for us. You can export or delete your data at any time from the app's settings.
Who we are
Walk Or Lose is a service operated by Alejandro Egea Aguilera, an individual (sole proprietor) established at Jenaro Checa 72, 50007 Zaragoza, Spain. As the operator, we are the controller of personal data processed through the Walk Or Lose app and website. You can reach us at support@walkorlose.com.
What we collect
Account information
- Name, email address, date of birth, country of residence
- A username and a profile photo if you set one
- Account password (hashed; we cannot see it)
Identity verification
For paid programs with returns over €600 in a calendar year, applicable law requires us to verify your identity. We collect a government-issued ID and a live selfie, processed by our identity-verification partner Persona. These are retained for the period required by financial regulators (typically 5 years) and never used for advertising.
Payment information
Card numbers, bank account numbers, and other payment instrument details are collected and stored by our payment processor, PayPal. We see only the last four digits, the brand, and the expiration date.
Step and activity data
- Daily and intraday step counts from Android Health Connect (or Google Fit where Health Connect is unavailable)
- Cadence and timestamp metadata used to detect anomalies (e.g. the distribution of steps across a day)
- Device pairing data (which step sources are linked to your account)
We do not collect heart rate, sleep, weight, blood pressure, menstrual data, calories burned, or any other health data exposed by Health Connect. We only request the step scope.
Device and usage data
- Device model, operating system version, app version
- IP address and approximate location (country / region only) used for jurisdiction enforcement and fraud detection
- Crash logs and basic analytics about which screens you visit
Why we collect it
We process personal data for the following purposes, on the legal bases noted:
- To run the service (contract) — accounts, step verification, taking your pledge, issuing returns and any bonus credit, customer support
- To process step & health data (explicit consent, Art. 9(2)(a) GDPR) — connecting a step source and counting your steps for your programs; you can withdraw consent at any time
- To comply with the law (legal obligation) — KYC for returns above thresholds, AML/CTF reporting, jurisdiction enforcement, tax summaries
- To prevent fraud and protect integrity (legitimate interest) — anomaly detection on step data, account-network analysis, dispute investigation
- To improve the product (legitimate interest) — aggregate analytics on app usage; never sold, never tied to identified accounts in our analytics tools
- To communicate (legitimate interest / consent) — program-related notifications (always), product news (opt-in)
Health & step data
Step data is special-category data. Because step and activity data can reveal information about your health, we treat it as special-category personal data under Article 9 GDPR. We process it only on the basis of your explicit consent, which you give when you connect a step source to Walk Or Lose, and which you can withdraw at any time by disconnecting the source or deleting your account (withdrawal does not affect processing carried out before withdrawal).
Step data is the core of the product and we treat it that way:
- Step data is never shared with advertisers, brokers, or any third party outside the limited service providers below.
- Other participants see only your program status — on track, did not complete, or grace-day used — never your raw step counts. Public profile counts are off by default.
- We do not infer health conditions, fitness levels, or any other sensitive attributes from your data, and we do not run advertising of any kind against step data.
On Android, our use of Health Connect data is also bound by Google's Health Connect policies, which prohibit selling it or using it for advertising. Our handling of Health Connect data complies with those policies.
Who we share it with
We share personal data only with the following categories of service providers, each bound by a data-processing agreement that limits them to processing data on our instructions:
- PayPal — payments, returns, card storage
- Persona — identity verification for returns above legal thresholds
- Amazon Web Services — cloud hosting (Frankfurt and Virginia regions)
- Sentry — crash reporting (PII scrubbed)
- Postmark — transactional email
- Zendesk — customer support tickets
We may also disclose data when legally compelled — a valid subpoena, court order, or a request from a financial regulator we are required to respond to. We publish a transparency report annually summarizing the number and type of these requests.
Do we sell data?
No. We do not sell personal data for money or for "valuable consideration." We do not share it for cross-context behavioral advertising. If you live in California, Colorado, Connecticut, or any other state with a consumer privacy law that asks about sale/share rights, the answer to "do you sell or share?" is no.
How long we keep it
- Account data: while your account is active, plus 30 days after deletion.
- Step data: while your account is active. Deleted with your account.
- Transaction records: 7 years from the transaction, to meet financial-record retention rules. Payment instrument details remain with PayPal per their retention schedule.
- Identity verification: 5 years from the date of verification.
- Support tickets: 2 years from last activity on the ticket.
- Server logs: 90 days.
Your rights
Depending on where you live, you have the right to:
- Access a copy of the personal data we hold about you
- Correct data that is inaccurate
- Delete your account and the associated data
- Export your data in a portable format (we provide JSON)
- Object to processing based on legitimate interests
- Withdraw consent where processing is based on consent
- Complain to your local data protection authority
You can exercise all of these from Settings → Privacy inside the app, or by emailing support@walkorlose.com. We respond within 30 days, usually much sooner.
Cookies & tracking
The Walk Or Lose website uses a minimum of cookies:
- A session cookie if you sign in on the web
- A cookie that remembers your cookie preferences (yes, really)
- First-party analytics from Plausible — anonymous, no cross-site tracking, no third-party sharing
We do not use Google Analytics, Facebook Pixel, or any advertising trackers. We do not need them.
Children
Walk Or Lose is not directed at children under 13, and our paid programs are not available to anyone under 18. If you believe a child has provided us with personal data, contact support@walkorlose.com and we will delete it.
International transfers
If you use the service from outside the European Economic Area, your data may be processed in the United States. Transfers from the EEA, UK, or Switzerland rely on the European Commission's Standard Contractual Clauses with all relevant service providers. Where applicable, we have implemented supplementary technical measures (encryption in transit and at rest, key management in the EEA, access controls).
Changes to this policy
If we change this policy in a way that affects your rights or what we do with your data, we'll let you know at least 30 days before the change takes effect — in the app, by email, or both. The current version always lives at this URL.
Contact
Walk Or Lose
Attn: Privacy
support@walkorlose.com