Legal Information — WalkingPlus UG

Effective date: May 2026 · Multi-Jurisdiction Legal Document

1. Impressum

WalkingPlus UG (haftungsbeschränkt)
Juri-Gagarin-Ring 130/0605
99084 Erfurt
Germany

Represented by (Geschäftsführerin): Maria Salzano
Commercial Register: Amtsgericht Jena
Registration Number: HRB 523949
VAT ID (USt-IdNr.): Application pending pursuant to § 27a UStG
Phone: +49 177 2727261
Email: info@walkingplus.net

Responsible for content under § 18 para. 2 MStV (German Media State Treaty): Maria Salzano (same address as above)

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2. Klara One — Development & Regulatory Status

Klara One is a mobility support system currently in the product development phase.

2.1 No medical claims

Information on this website about Klara One is provided for general transparency about a product in development. It does not constitute medical, physiotherapeutic, rehabilitation, diagnostic, preventive, or therapeutic advice in any jurisdiction.

Klara One is not intended to diagnose, treat, cure, or prevent any disease.

The contents of this website have not been reviewed or validated by any health authority.

2.2 Regulatory classification

The regulatory classification of Klara One is currently under assessment. The final classification will be determined as part of the conformity assessment process in accordance with the rules of Annex VIII of MDR (EU) 2017/745.

2.3 Patent notice

Klara One technology is the subject of the following patent applications: (i) Italian patent application IT 102025000009135, filed on 23 April 2025 with the Italian Patent and Trademark Office (UIBM); (ii) European patent application EP26172956.0, filed on 17 April 2026 with the European Patent Office (EPO). Both applications are classified under IPC A61H 3/00. The patent application is registered in the name of Maria Salzano. Commercialization and economic exploitation are carried out by WalkingPlus UG. Any unauthorized reproduction, adaptation or exploitation is prohibited.

2.4 Market placement restriction

Klara One has not yet completed the CE conformity assessment process as a finalized medical device and therefore may not currently be placed on the market or advertised as such, where prohibited by applicable law.

The completion of the regulatory path (CE marking, ISO 13485 Quality Management System certification, clinical validation) proceeds progressively in line with the securing of the necessary financial resources. WalkingPlus UG is currently engaged in fundraising activities through public funding, private investors and sponsorship.

2.5 Testing and development phase

Any product testing takes place exclusively within controlled internal development and evaluation phases.

3. Privacy Policy — Overview & Controller

This Privacy Policy explains how WalkingPlus UG collects, uses, discloses, and safeguards personal data through the website www.walkingplus.net.

Data Controller / Business / Organization: WalkingPlus UG (haftungsbeschränkt), contact details in section 1.
Privacy contact: privacy@walkingplus.net
Data Protection Officer (DPO): not currently designated as WalkingPlus UG does not meet the criteria for mandatory designation under Art. 37 GDPR and § 38 BDSG. Designation will be evaluated upon completion of the test phase with volunteer testers.

3.1 Universal principles applicable across all jurisdictions

• Lawfulness, fairness, transparency: we process personal data only for clearly stated purposes.
• Purpose limitation & data minimisation: we collect only what is necessary.
• Accuracy & storage limitation: we keep data accurate and only as long as necessary.
• Security: appropriate technical and organisational measures in place.
• No sale of personal information in the meaning of the CCPA/CPRA. We do not sell or "share" (for cross-context behavioural advertising) your personal information. See section 7.
• No use of automated decision-making producing legal or similarly significant effects.

3.2 Categories of personal data processed

We do not knowingly process: government IDs, financial account data, biometric data, precise geolocation, health data, sexual-orientation data, or data of children below the applicable age thresholds under local law, without verifiable parental consent.

3.3 Categories of recipients / Sub-processors

WalkingPlus UG uses the following external providers that may process personal data for technical website operation purposes:

This list will be updated when new providers are added.

4. Privacy Notice — European Union / EEA 🇪🇺

This section applies to data subjects located in the EU and EEA and supplements section 3.

4.1 Legal bases (Art. 6 GDPR)

4.2 Your rights under GDPR

Access (Art. 15) · Rectification (Art. 16) · Erasure (Art. 17) · Restriction (Art. 18) · Portability (Art. 20) · Objection (Art. 21) · Withdraw consent (Art. 7(3)) · Lodge complaint (Art. 77).

Competent supervisory authority: Thüringer Landesbeauftragter für den Datenschutz und die Informationsfreiheit (TLfDI) — tlfdi.de. You may also complain to your local DPA.

4.3 International transfers

Where any processor is established outside the EEA, transfers are safeguarded under Art. 46 GDPR via Standard Contractual Clauses and supplementary measures pursuant to Schrems II.

4.4 Retention

• Contact-form data: up to 6 months unless statutory retention applies.
• Newsletter: until consent is withdrawn.
• Server logs: max 7 days.
• Statutory retention (HGB, AO): up to 10 years.

4.5 Personal data breach notification

In the event of a personal data breach, WalkingPlus UG notifies the competent supervisory authority (TLfDI) within 72 hours of becoming aware of the breach pursuant to Art. 33 GDPR. Where the breach is likely to result in a high risk to the rights and freedoms of data subjects, WalkingPlus UG also notifies the affected data subjects without undue delay pursuant to Art. 34 GDPR.

5. Privacy Notice — United Kingdom 🇬🇧

This section applies to data subjects in the United Kingdom and supplements section 3. Processing is governed by the UK GDPR and the Data Protection Act 2018.

Lawful bases: as per section 4.1, applied under UK GDPR Art. 6.
UK Representative (Art. 27 UK GDPR): not currently appointed.
Supervisory authority: Information Commissioner's Office (ICO) — ico.org.uk.
Cookies: consent required under PECR — see section 10.

6. Privacy Notice — Switzerland 🇨🇭

This section applies to data subjects in Switzerland under the revised Federal Act on Data Protection (revFADP), in force since 1 September 2023.

Controller: WalkingPlus UG — see section 1.
Swiss representative (Art. 14 revFADP): not currently appointed.
Rights: access, rectification, erasure, objection, data portability, and to lodge a complaint with the FDPIC — edoeb.admin.ch.

7. Privacy Notice — United States 🇺🇸

7.1 California — CCPA / CPRA

This section applies to "consumers" as defined in the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act.

7.1.1 Categories of personal information collected (last 12 months)

7.1.2 Sale, sharing, retention

WalkingPlus UG does not sell personal information and does not "share" personal information for cross-context behavioural advertising as those terms are defined in the CPRA. Retention periods are set out in section 4.4 above.

7.1.3 Your California rights

• Right to know what personal information we collect, use, disclose
• Right to delete personal information
• Right to correct inaccurate personal information
• Right to opt-out of sale/sharing (not applicable — we do neither)
• Right to limit use of sensitive personal information (not applicable — we do not collect SPI)
• Right to non-discrimination for exercising your rights
• Right to designate an authorised agent

To exercise these rights: email privacy@walkingplus.net with subject line "California Privacy Request". We respond within 45 days, extendable by 45 additional days where reasonably necessary.

"Shine the Light" (Cal. Civ. Code § 1798.83): California residents may request information about disclosures of personal information to third parties for those parties' direct marketing. We do not make such disclosures.

7.1.4 Global Privacy Control (GPC)

We honour browser-based opt-out signals such as the Global Privacy Control (GPC).

7.2 Other U.S. state privacy laws

Residents of the following states have substantially similar rights — Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Oregon (OCPA), Texas (TDPSA), Montana (MTCDPA), Iowa (ICDPA), Tennessee (TIPA), Indiana (INCDPA), Delaware (DPDPA), New Jersey (NJDPA), New Hampshire (NHDPA), Maryland (MODPA). Contact privacy@walkingplus.net specifying your state of residence.

7.3 Federal U.S. framework

• FTC Act, Section 5: we comply with prohibitions on unfair or deceptive practices.
• HIPAA: WalkingPlus UG is not a Covered Entity or Business Associate. HIPAA does not apply.
• COPPA: we do not knowingly collect personal information from children under 13.
• CAN-SPAM Act: see section 11.
• ADA: see section 15 (Accessibility).

8. Privacy Notice — Canada 🇨🇦

For Canadian residents, processing is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws (e.g., Quebec's Law 25, Alberta PIPA, BC PIPA).

• Accountability: WalkingPlus UG is responsible for personal information under its control.
• Consent: meaningful consent is obtained for collection, use, and disclosure.
• Access & correction rights: contact privacy@walkingplus.net.
• Complaints: Office of the Privacy Commissioner of Canada — priv.gc.ca; for Québec residents, the Commission d'accès à l'information.
• CASL: see section 11.

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9. Privacy Notice — Rest of World

If you reside in a jurisdiction not specifically addressed above, WalkingPlus UG processes your personal data in accordance with:

1. The principles of the GDPR as a baseline standard;
2. Any mandatory local law that applies because the company directs activities to that jurisdiction.

Visitors in Australia (Privacy Act 1988), Brazil (LGPD), Japan (APPI), South Korea (PIPA), Singapore (PDPA), India (DPDP Act 2023), South Africa (POPIA), and the UAE (PDPL) may contact privacy@walkingplus.net to exercise rights granted to them under applicable local law.

10. Cookie Policy

Cookies and similar technologies are used on this website. Consent rules differ by region:

10.1 Categories of cookies

• Strictly necessary — required for site functionality. Always active.
• Analytics — only with consent (EU/UK).
• Preferences — only with consent.
• Marketing / advertising — currently not used.

10.2 Consent management

A cookie banner allows you to accept, reject, or selectively choose non-essential cookies. You may change your choice via the "Cookie settings" link in the footer at any time.

10.3 Tools currently in use

As of the effective date, the website uses the following tools that set cookies or equivalent technologies:

• Iubenda (Iubenda S.r.l., Italy) — cookie consent management (technically necessary cookies). Legal basis: legal obligation (Art. 6(1)(c) GDPR).
• Cloudinary (Cloudinary Ltd, USA/EU) — hosting of optimized website images (technically necessary caching cookies). Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

Any additional tools (analytics, marketing) will be added to this list before activation, with explicit consent where required.

11. Email Marketing & Anti-Spam

Where you subscribe to communications from WalkingPlus UG, we comply with applicable anti-spam laws:

• EU/EEA & UK: Art. 6(1)(a) GDPR and § 7(2) UWG / PECR — double opt-in, clear identification of sender, one-click unsubscribe.
• USA — CAN-SPAM Act: truthful headers, valid physical postal address, clear opt-out honoured within 10 business days.
• Canada — CASL: express or implied consent, sender identification, functional unsubscribe link.
• Australia — Spam Act 2003: consent, identify, unsubscribe.

To unsubscribe at any time: use the link in any marketing email or write to privacy@walkingplus.net.

12. Terms of Use

12.1 Acceptance

By accessing this website you agree to these Terms.

12.2 Eligibility & geographic restriction

This website is intended for users aged 18 or above. Klara One is not commercially offered or publicly distributed in any jurisdiction where this would be unlawful or where regulatory clearance has not been obtained.

12.3 Informational nature

All content is for general informational purposes only and does not constitute medical, legal, financial, or other professional advice.

12.4 Permitted use

Personal, non-commercial information use only. No scraping, mirroring, framing, reverse engineering, or use that violates law or third-party rights.

12.5 Third-party links

Links to third-party sites are provided for convenience. WalkingPlus UG does not control and is not responsible for third-party content.

13. Intellectual Property & Patent Notice

13.1 Copyright

All content on this website — text, images, graphics, design, and code — is protected by copyright and related rights under German, EU, and international copyright treaties (Berne Convention, WIPO) and belongs to WalkingPlus UG. Unauthorized reproduction, distribution or commercial use is prohibited.

13.2 Designations

"WalkingPlus" and "Klara One" are used by WalkingPlus UG in commercial business. Trademark registrations (both Italian and European EUIPO) are planned for the future and not currently filed. The initiation of the registration procedure is subject to the availability of adequate financial resources, currently being raised through self-financing, public funding instruments (e.g., Innovationsgutschein InnoSecure Thüringen), private investments and sponsorship.

13.3 Patent

(i) Italian patent application IT 102025000009135, filed on 23 April 2025 with the Italian Patent and Trademark Office (UIBM); (ii) European patent application EP26172956.0, filed on 17 April 2026 with the European Patent Office (EPO). Both applications are classified under IPC A61H 3/00. The patent application is registered in the name of Maria Salzano. Commercialization and economic exploitation are carried out by WalkingPlus UG. Any unauthorized reproduction, adaptation or exploitation is prohibited.

13.4 DMCA Notice (USA)

If you believe your copyright has been infringed by content on this site, you may submit a notice under 17 U.S.C. § 512(c) to: info@walkingplus.net, with the elements required by the DMCA.

14. Limitation of Liability

14.1 General

The website is provided "as is". To the maximum extent permitted by mandatory law, WalkingPlus UG disclaims all warranties of merchantability, fitness for a particular purpose, accuracy, and non-infringement.

14.2 Germany / EU

• Unlimited liability for intent, gross negligence, injury to life, body, or health.
• For simple negligence: limited to breach of essential contractual duties (Kardinalpflichten) and capped at typical foreseeable damage.
• Liability under the German Produkthaftungsgesetz remains unaffected.

14.3 USA

Some U.S. states do not allow exclusion or limitation of certain warranties or liabilities. In those states, the above limitations apply only to the extent permitted by law.

14.4 Reliance disclaimer

No reader should make any health, mobility, purchasing, investment, or business decision in reliance on information published on this website during the pre-market phase.

14.5 No investment offer

The contents of this website do not constitute a public offering of securities or investments, nor a solicitation to invest under applicable law.

14.6 No warranty

WalkingPlus UG provides no warranty as to the completeness, accuracy, or future availability of the product features described or of regulatory authorizations.

15. Accessibility Statement

WalkingPlus UG is committed to digital accessibility for people with disabilities. We are progressively working towards conformity with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. The website has not yet undergone a full accessibility audit; any barriers encountered by users may be reported to the contacts at the end of this page.

15.1 Applicable standards

• EU: European Accessibility Act (EAA, Directive 2019/882) — applicable from 28 June 2025.
• USA: Americans with Disabilities Act (ADA) — Title III principles.
• Germany: Barrierefreiheitsstärkungsgesetz (BFSG) — applicable from 28 June 2025.

15.2 Feedback

If you encounter accessibility barriers on this website, please contact info@walkingplus.net.

16. Dispute Resolution & Governing Law

16.1 Governing law

These Terms and any non-contractual obligations arising in connection with them are governed by the laws of the Federal Republic of Germany, excluding its conflict-of-laws rules and the UN Convention on Contracts for the International Sale of Goods (CISG). Mandatory consumer protection law of a consumer's country of habitual residence remains unaffected.

16.2 Jurisdiction

For merchants and legal entities under public law: Erfurt, Germany. For consumers: their habitual-residence courts as provided by mandatory law.

16.3 EU Online Dispute Resolution Platform

Platform under Article 14(1) of Regulation (EU) No 524/2013: https://ec.europa.eu/consumers/odr/.

16.4 Consumer arbitration (VSBG, Germany)

Pursuant to § 36 VSBG, WalkingPlus UG declares: we are neither willing nor obliged to participate in dispute resolution proceedings before a consumer arbitration board.

16.5 USA — informal resolution

U.S. residents agree to attempt to resolve any dispute informally by contacting info@walkingplus.net first.

17. Changes to this Notice

We may update this Legal Information from time to time. The "Effective date" at the top will indicate the latest revision. Material changes will be communicated via a banner on the website.

18. Contact

Note: for California Privacy Requests, please use subject line "California Privacy Request".

Response times: general inquiries within 10 business days; GDPR requests within one month (Art. 12(3) GDPR); CCPA requests within 45 days (extendable by 45).