This Privacy Policy explains how Walle collects, uses and protects information when businesses use our platform to issue digital loyalty cards, and when their customers receive and use those cards in Apple Wallet, Google Wallet or as PWA passes.
Who we are
Walle is a SaaS loyalty platform operated by Sole proprietor (FOP) Khomyn D. D. (tax ID 3684101018), Ukraine. For any privacy question or request, contact us at dxesto@gmail.com or via the in-product support form.
What information we collect
We only collect data that is necessary to operate the loyalty service:
- Business account data — business name, the owner's phone number, password (hashed), the Telegram account used to verify that number, billing details (card brand and last digits, never the full card number) and branding assets you upload.
- Customer data your business chooses to collect — typically name, email, phone, date of birth, and the loyalty balance/stamp history tied to each issued card.
- Wallet pass data — device push tokens supplied by Apple Wallet and Google Wallet so we can update your installed pass (e.g. balance changes, geofence updates).
- Technical data — IP address, browser/OS and server logs needed to run and secure the service. We do not use analytics or advertising trackers.
How we use this data
We use the data above to: create and update digital loyalty cards in Apple Wallet and Google Wallet; deliver push notifications and geofence updates to installed passes; let businesses run their own loyalty programmes and contact their own customers; bill businesses for their plan; investigate fraud or abuse; and improve the product.
Legal bases (GDPR)
For business users, processing is based on the contract you accept when signing up. For customers of those businesses, the business is the data controller and Walle acts as a processor on their behalf. Where we process data on our own account (security, fraud prevention) we rely on legitimate interest. We do not send marketing emails.
Who we share data with
We do not sell personal data. We share data only with the processors required to deliver the service:
- Apple Inc. — to issue and update Apple Wallet passes (PassKit Web Service).
- Google LLC — to issue and update Google Wallet passes (Google Wallet API).
- Vercel Inc. — application hosting, edge delivery, log storage.
- Telegram — to verify the business owner's phone number at signup and to deliver password-reset links. WayForPay — to process subscription payments.
How long we keep data
Account data is retained for as long as the business account is active and for up to 24 months after closure for accounting and legal reasons. Customer pass data is kept for as long as the issuing business keeps the card active; if the business asks us to delete a customer or a card, the related data is removed within 30 days of the request.
Your rights
Under GDPR and similar laws, you have the right to access, correct, export or delete your personal data, object to certain processing, and lodge a complaint with your local data-protection authority. To exercise any of these rights, email dxesto@gmail.com. If you are a customer of a business using Walle, please contact that business first — they decide what data is collected on their card.
International transfers
Walle is operated from Ukraine. Some processors (Apple, Google, Vercel) may process data in the United States or other countries. Where applicable, transfers are covered by Standard Contractual Clauses or equivalent safeguards.
Children
Walle is a B2B service intended for businesses and adult customers. We do not knowingly collect data from children under 16. If a business issues a loyalty card to a minor, the business is responsible for obtaining the necessary parental consent.
Cookies and tracking
We use a small number of strictly necessary cookies for authentication and locale preference. We do not use analytics cookies, third-party advertising cookies or cross-site trackers.
Changes to this policy
We may update this policy from time to time. The "Last updated" date at the top reflects the latest revision. Material changes will be communicated to active business accounts in the dashboard and via Telegram.
Contact
Questions about this policy or about how your data is handled? Email dxesto@gmail.com or use the support form.