Last Updated: February 9, 2026

This Privacy Policy describes how WEBNUM LLC collects, uses, processes, shares, and protects Your information when You use the CalWay mobile application, website, and related services (collectively, the “Service”). By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Interpretation and Definitions
   1.1 Interpretation
   Capitalized terms have the meanings assigned to them in this Policy.

1.2 Definitions
Account means the unique profile created for You to access the Service.
Application means the mobile application titled “CalWay – AI Calorie Tracker.”
Company, We, Us, or Our means WEBNUM LLC, a limited liability company registered in Uzbekistan, with business address at Tashkent, Uzbekistan.
Device means any device used to access the Service.
Personal Data means information that identifies or can reasonably be linked to an individual. Personal Data includes identifiable health information.
Health Data means information You provide relating to Your physical characteristics, health, nutrition, goals, or activity, including weight, height, food logs, health attributes, body composition, and progress photos.
Usage Data means data collected automatically through use of the Service, including device information, activity logs, and analytics data.
User Content means photos, images, text, food entries, metadata, or other inputs You upload or submit through the Service.
Website means getcalway.com.
You means the individual using the Service or the organization on whose behalf the Service is used.

2. Types of Data We Collect
   We collect the categories of data described below. Certain categories may qualify as health information, sensitive personal information, or biometric-adjacent data under various privacy laws.

2.1 Personal Data You Provide
We may collect the following Personal Data when You create an Account or use the Service:

First name
Last name
Email address
Optional profile details You provide

2.2 Health and Nutrition Data
To provide calorie estimation and nutrition tracking features, We collect:

Weight
Height
Food logs and food data (including items photographed, scanned, or logged manually)
Progress photos
Nutrition goals
Daily calorie intake and macronutrient data
Exercise and activity information (if provided)
Any other health information You choose to enter into the Application

You decide which health information to provide. The Service cannot function properly without basic nutrition data, such as food entries and photos.

2.3 User Content (Including Photos)
User Content includes:

Photos of food uploaded for AI-powered calorie analysis
Progress photos
Text entries and logs
Manual food entries
Notes and comments

Important: We may use anonymized or aggregated food images to improve Our AI models, algorithms, and product features. We do not associate such images with Your identity when used for internal development.

2.4 Usage Data
We automatically collect:

Device type, operating system, and app version
IP address
Time stamps and activity logs
Crash data and error reports
Feature usage analytics
Performance data
Session information

This data helps Us secure, improve, and optimize the Service.

2.5 Cookies and Tracking Technologies
The Website uses cookies, tags, and similar technologies for analytics, functionality, and security. The Application may use mobile identifiers for analytics and performance tracking.

3. How We Use Your Data
   We use the collected data for the following purposes:

3.1 To Provide and Improve the Service
AI-powered food identification and calorie estimation
Nutrition tracking and meal logging
Personalized recommendations and insights
Calorie goal calculations
Machine learning model improvement
Account management
Service stability, debugging, and optimization

3.2 To Improve AI and Computer Vision Models
We use food images and related User Content to:

Train and improve AI models
Enhance accuracy of calorie estimates and food recognition
Improve overall product performance and user experience

Such use is strictly anonymized or aggregated and not linked to Your identity.

3.3 Communications
We may contact You about:

Updates and new features
Service-related notifications
Customer support responses
Account-related information

3.4 Marketing (Optional)
We may send You promotional emails, newsletters, or special offers unless You opt out. You can unsubscribe at any time.

3.5 Legal and Compliance
We may use Your data to:

Detect or prevent fraud and abuse
Comply with law enforcement obligations
Protect Our rights and the rights of users
Enforce our Terms of Service

3.6 Business Transfers
If We engage in a merger, acquisition, financing, or asset sale, Your information may be transferred as permitted by law. We will notify You of any such change.

4. Legal Bases for Processing (For GDPR-Covered Users)
   Where applicable under the General Data Protection Regulation (GDPR), We rely on:

Consent – for certain data processing activities
Contract performance – to provide the Service You’ve requested
Legitimate interests – such as service improvement, security, and analytics
Legal obligations – to comply with applicable laws

5. How We Share Personal Data
   We may share Personal Data in the following circumstances:

5.1 Service Providers
With trusted third-party vendors who support the Service, such as:

Cloud hosting and storage providers
Analytics providers
Customer support tools
Payment processors (if applicable)
AI and machine learning service providers

These providers are contractually obligated to protect Your data and use it only for specified purposes.

5.2 Business Transfers
As part of corporate transactions, such as mergers, acquisitions, or asset sales.

5.3 Legal Compliance
With law enforcement, regulators, or other authorities when legally required or to protect legal rights.

5.4 With Your Consent
Where You explicitly direct Us to share information with third parties.

5.5 Aggregated or Anonymized Data
We may share aggregated, de-identified, or anonymized data for analytics, research, or business purposes. Such data cannot be used to identify You.

We do not sell Your Personal Data to third parties.

6. User Content and License Rights
   By submitting User Content, You grant the Company a worldwide, royalty-free, non-exclusive, sublicensable license to use, store, process, reproduce, modify, and create derivative works from Your User Content solely to operate, maintain, and improve the Service, including internal AI model training.

We do not publicly display Your photos or content without Your express consent.

Progress photos are never used for AI model training or shared externally.

Food photos may be used in anonymized form to improve our AI algorithms.

7. Retention of Data
   We retain:

Personal Data for as long as Your Account is active or as necessary for the purposes described in this Policy
Health Data until You delete it or delete Your Account
Usage Data for a shorter period unless needed for security, legal compliance, or service improvement
Backups for limited periods as part of standard data retention practices

We delete or anonymize data when no longer needed unless legally required to retain it.

8. Data Transfers
   Your information may be transferred to and processed on servers located outside Your jurisdiction, including but not limited to servers in the United States and Europe. We implement appropriate safeguards as required by law, including standard contractual clauses for international transfers where applicable.
9. Your Privacy Rights
   Depending on Your jurisdiction, You may have the following rights:

Access Your Personal Data and request a copy
Correct inaccurate or incomplete data
Delete Your Personal Data (“right to be forgotten”)
Export Your data in a portable format
Withdraw consent where processing is based on consent
Object to certain processing activities
Request restriction of processing
Lodge a complaint with a supervisory authority

You may exercise these rights through in-app settings or by contacting Us at info@getcalway.com.

10. Deleting Your Personal Data
    You may request deletion of:

Your Account
Progress photos
Food logs and meal history
Profile data and personal information

To request deletion, contact us at info@getcalway.com or use the in-app account deletion feature. Some data may persist in backups or where legally required.

11. Security
    We implement administrative, technical, and physical safeguards designed to protect Your data, including:

Encryption of data in transit and at rest
Access controls and authentication
Regular security assessments
Secure cloud infrastructure

However, no online system is entirely secure, and We cannot guarantee absolute security.

12. Children’s Privacy
    The Service is not intended for individuals under 13 years of age. We do not knowingly collect personal information from children under 13. If You believe We have collected information from a child under 13, please contact Us immediately at info@getcalway.com.
13. Third-Party Links and Services
    The Service may contain links to third-party websites, applications, or services. Their privacy practices are governed by their own policies, and We do not control or endorse them. We encourage You to review their privacy policies.
14. Changes to This Privacy Policy
    We may update this Privacy Policy from time to time to reflect changes in Our practices or legal requirements. Updates become effective when posted to this page. We may notify You by email or through the Application for material changes. Your continued use of the Service after changes constitutes acceptance of the updated Policy.
15. International Users
    CalWay is operated from Uzbekistan. If You access the Service from outside Uzbekistan, Your information may be transferred to, stored, and processed in jurisdictions with different data protection laws than Your own.
16. California Privacy Rights (CCPA)
    If You are a California resident, You may have additional rights under the California Consumer Privacy Act (CCPA), including:

The right to know what Personal Data We collect
The right to delete Personal Data
The right to opt-out of the sale of Personal Data (We do not sell Personal Data)
The right to non-discrimination for exercising Your rights

To exercise these rights, contact Us at info@getcalway.com.

17. Contact Us
    If You have questions, concerns, or requests related to this Privacy Policy or Your privacy rights, You may contact Us:

Email: info@getcalway.com
Website: getcalway.com
Company: WEBNUM LLC
Address: Tashkent, Uzbekistan

We will respond to Your inquiry within a reasonable timeframe as required by applicable law.