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Privacy Policy

Effective Date: March 2026

Introduction

This Privacy Notice will inform you as to how CalMentor ("Company", "we", "us" and "our") collects and processes information about you and in particular, your personal data. We hereby assure you that this Privacy and Personal Data Protection Policy ("Privacy Policy") fully respects and complies with the EU Regulation 679/2016 ("GDPR") and applicable data protection laws.

Useful Definitions

Personal Data means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, address, contact details, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing means any operation or set of operations which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

The Controller

Regarding the personal data, and in cases we determine the purposes and means of the processing, the Controller is: CalMentor, email: support@calmentor.com.ua

Principles We Adhere To

At CalMentor, we are committed to adhering to the following principles of processing personal data in accordance with Article 5 of the GDPR:

Lawfulness, fairness and transparency: Personal data is processed lawfully, fairly and in a transparent manner
Purpose limitation: Data is collected for specified, explicit and legitimate purposes
Data minimisation: Data is adequate, relevant and limited to what is necessary
Accuracy: Data is accurate and kept up to date
Storage limitation: Data is kept only as long as necessary
Integrity and confidentiality: Data is processed securely with appropriate technical measures

Collection of Personal Data

We collect Personal Data from you in the following cases:

When you create an account in the CalMentor app
When you use our calorie tracking and food logging features
When you take photos of food for AI analysis
When you use the AI assistant chat feature
When you track your weight, fasting, or other health metrics
When you contact us directly through email or support channels
When you subscribe to premium features

Minors' Personal Data

Our services are intended for users aged 13 years or older. We collect and process minors' personal data only after verifiable parental consent. If you are under 13, please do not use our services.

Categories of Personal Data We Collect

Data from the following categories may be collected and processed:

Account Information: Email address, name, profile preferences
Health and Nutrition Data: Weight, height, calorie goals, food logs, nutritional intake, fasting records, water consumption
Photos: Food photos you capture for AI-powered calorie estimation
Usage Data: App interactions, feature usage, preferences, device information
Payment Information: Transaction details for premium subscriptions (processed by Apple)
Communication Data: Messages sent through our AI assistant, support inquiries

Purposes of Processing & Legal Bases

The processing of personal data is based on the following legal bases as referred to in Article 6 of the GDPR:

Consent (Article 6.1.a)

When you voluntarily provide health data for tracking purposes
When you upload food photos for AI analysis
When you opt-in to receive notifications or marketing communications

Performance of a Contract (Article 6.1.b)

To provide the calorie tracking and nutrition services you requested
To process premium subscription purchases
To sync your data across devices via cloud services

Legitimate Interests (Article 6.1.f)

To improve our AI models and service quality (using anonymized data)
To prevent fraud and ensure security of our services
To analyze usage patterns and improve user experience

Third-Party Services

We use the following third-party services to provide our app functionality:

OpenAI: For AI-powered food recognition, nutritional analysis, and chat assistant features. Food photos and text are sent to OpenAI's API for processing.
Cloudflare: For secure data storage, content delivery, and backend services
Apple HealthKit: Optional integration for syncing health data (only with your explicit permission)
Supabase: For user authentication and account management

Important: When you use our photo recognition or AI chat features, your data is processed by OpenAI. Please review OpenAI's Privacy Policy for information about how they handle data.

Data Retention Period

We store personal data for as long as it is required by the respective processing purpose:

Account data: Retained while your account is active and for 30 days after deletion request
Food logs and health data: Retained while your account is active; you can delete specific entries at any time
Photos: Processed temporarily for AI analysis; stored only if you choose to save them
Chat history: Retained for 90 days for service improvement, then anonymized or deleted

How We Ensure Security of Personal Data

We have implemented reasonable organisational and technical measures to protect your personal data:

All data is encrypted in transit (TLS/SSL) and at rest
Access to personal data is restricted to authorized personnel only
We use Cloudflare's enterprise-grade security infrastructure
Regular security audits and vulnerability assessments
Secure authentication with token-based access control

Data Storage Location

Your data is stored on Cloudflare's global infrastructure, primarily within the European Economic Area (EEA) and regions with adequate data protection standards. Data processed by OpenAI may be transferred to the United States under appropriate safeguards.

Your Rights as a Data Subject

Under the GDPR, you have the following rights:

Right of access: Obtain confirmation of whether your personal data is being processed and access to that data
Right to rectification: Request correction of inaccurate personal data
Right to erasure ('right to be forgotten'): Request deletion of your personal data when it is no longer necessary
Right to restriction: Request restriction of processing in certain circumstances
Right to data portability: Receive your data in a structured, commonly used format
Right to object: Object to processing based on legitimate interests or for direct marketing
Right to withdraw consent: Withdraw your consent at any time where processing is based on consent

To exercise any of these rights, please contact us at support@calmentor.com.ua. We will respond within one month of receiving your request.

Data Export and Deletion

You can export or delete your data at any time through the app settings:

Go to Settings → Account → Export Data to download all your information
Go to Settings → Account → Delete Account to permanently remove all your data

Personal Data Breach

In the event of a breach of security affecting your personal data, we will:

Assess the breach and implement measures to limit its impact
Notify the relevant supervisory authority within 72 hours if required
Notify you directly if the breach poses a high risk to your rights and freedoms
Take measures to prevent similar incidents in the future

Links to Other Websites

Our app may contain links to other websites or services. We are not responsible for the privacy practices of these third parties. We recommend reviewing their privacy policies before providing any personal information.

Children's Privacy

CalMentor is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected data from a child under 13, we will take steps to delete that information promptly.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

Email: support@calmentor.com.ua

Policy Updates

This policy may be updated from time to time. We will notify you of any significant changes through the app or via email. The effective date at the top of this page indicates when this policy was last revised.