This Privacy Policy (“Policy”) describes how Cal AI, Inc. (“Cal AI,” “we,” “our,” or “us”)
collects, uses, discloses, and otherwise processes your personal information when you use our
Services (use of our Site, Mobile App, and other interactions you may have with us), as well as
your privacy rights and choices regarding your personal information.
This Policy forms a part of our Terms of Service and terms not defined in this
Policy are defined in the Terms of Service.
If you reside in the U.S. and are under 13 years of age, you should not use our Services. If we
become aware that an individual under 13 years of age may have provided us with personal
information, we will investigate and, if applicable, take steps to remove and delete the data
and delete that individual’s account. If you reside in the European Economic Area, Switzerland,
or United Kingdom, please see the
Additional Information for Certain Jurisdictions
section below.
What’s New in this Version
This Policy updates our previous version (dated 11/25/25) with a user-friendly format and
streamlines how our users can exercise their privacy rights.
Personal Information We Collect
We may collect personal information directly from you, automatically through your use of the
Services, and from third parties.
Personal Information We Collect Directly from You
Account and Profile Information. This includes your name, email address,
general location information (country/zip code), profile image or photo (optional), gender, and
date of birth.
Food and Activity Data. Certain features of our Services allow you to
voluntarily share information about your dietary habits and activities you engage in. This
includes your:
Dietary habits;
Food, drink, and medications you consume (including as submitted via voice and image logging);
Calorie count;
Dietary restrictions;
Fitness level, activity, and goals (e.g., weekly goals or habits like eat more protein);
Body measurements (e.g., height, weight, and BMI);
Information related to any physiological conditions;
Progress photos you may choose to provide; and
Food and Activity Data may include sensitive personal information when the
information indicates or allows someone to infer a health condition.
Communications with Cal AI. This includes your email address, name, and any
other content provided when you communicate with us, including exchanges with our customer
support personnel and chatbot.
Communications and information exchanged with other users and posted in community
forums and online discussion groups through our Groups feature. This includes posted
content and related contact information you provide when interacting within public and private
groups, such as your name, email address, diary entries, photos, fitness goals, and
achievements.
Research and Survey information. This may include information you provide if
you participate in research and surveys, such as contact information, feedback, and other
information you choose to provide.
Events and Registration Details. This may include information related to your
participation in our events (if any) as may be collected when you register for such events.
For example, if you register for or attend an event that we host or sponsor, we will collect
information related to your registration for and participation in such event.
Preferences and Other Requests. This may include information about your
preferences, including communication preferences, preferences related to your use of the
Services, and any other preferences or requests you provide when interacting with us.
Payment information. Purchases and subscriptions are processed through
third-party platforms such as the Apple App Store and Google Play Store. Their terms govern
payment processing, renewals, and refunds.
Personal Information We Collect Automatically
Cal AI may collect Usage and Device Data. This may include details about your
browser, operating system, or device (such as your cookie identifiers, internet protocol (IP)
address, mobile advertising identifier, and other unique identifiers), internet service
provider, mobile carrier, general location information (including inferred location based off of
your IP address), actions that you take while using the Services, information about how you
interact with the Services, including the frequency and duration of your activities, information
about the links you click, and other information about how you use the Services.
Cal AI may collect information, such as usage and device data, from you automatically through
cookies and other tracking technologies (collectively, “Cookies”) we use to enhance your
experience when you use our Services.
We use Cookies for a variety of purposes, including to make our site work, ensure security, and
prevent fraud (Required Cookies); to provide enhanced functionality and analyze usage to improve
our website (Functional Cookies); and to provide you with personalized content and
advertisements (Targeted Advertising Cookies).
What are Cookies? “Cookies” are small text files that are placed on your device
when you visit certain websites. Like many other online service providers, we (and our
third-party service providers and partners) use cookies and other similar technologies (e.g.,
pixels, web beacons, local storage objects, log files, software development kits, etc.) on the
Services for various purposes. We collect information through cookies through those we set
directly (“First-Party Cookies”) and those set by third parties (“Third-Party Cookies”).
Managing your Cookie Preferences. Depending on the country where you reside,
you have choices with respect to Cookies. For example, by modifying your browser preferences,
you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all
cookies. If you choose to reject all cookies, some of our Service’s features may not work
properly. You can also adjust your in-app cookie choices at any time by visiting
.
Personal Information We Receive From Third Parties
We may receive information about you from other sources, such as through third-party connected
health devices, service providers, research partners, marketing and advertising partners, and
social media platforms.
Social login providers. We may receive information from third-party providers
(like Apple and Google) if you sign in using your account with one of these providers.
Service providers. Our service providers may provide us with your information
to enrich our Services. For example, we may collect information about how you use our Services
to improve our user experience and ensure the security of our Services. We also use service
providers to help us communicate with you when you have questions or information requests.
Research partners. We may collect information for research purposes and
surveys we conduct. This may include demographic information, health and fitness goals, and
input regarding the use of our Services.
Marketing and advertising companies. This includes third parties who may
disclose information about your interests, demographic information, and information about the
marketing and advertisements you have seen or clicked on.
Business partners. We may partner with other businesses to offer the
Services. We may receive your personal information from those business partners as necessary
or appropriate for the purposes listed in this Policy.
Information provided by other Cal AI users. We may receive personal
information about you provided by other Cal AI users (like shared content, photos, or
achievements) through Group Channels.
Connected data. With your permission, we may also collect relevant data from
your device’s health and fitness repository, such as Apple’s HealthKit or Android’s Google
Health Connect.
The information you provide to HealthKit is then governed by the Apple Terms and
Conditions and Privacy Policy. The unique information you choose to send from HealthKit is
not used by Cal AI for marketing and advertising or transferred by Cal AI to third parties
for marketing and advertising.
The information you provide to Google Health Connect is then governed by the Android Terms
and Conditions and Privacy Policy. The unique information you choose to send from Google
Health Connect is not used by Cal AI for marketing and advertising or transferred by Cal AI
to third parties for marketing and advertising.
Aggregated, Deidentified, or Anonymized Information
Please note that we may aggregate, de-identify, or anonymize information so that it will no
longer be considered personal information under applicable law. We may use and disclose
de-identified information for purposes consistent with those described in this Policy or as
otherwise permitted by applicable law.
How We Use Personal Information
Provide our Services. We use your personal information in connection with the
provision, administration, and management of the Services, including managing your account,
providing troubleshooting and technical support, and otherwise running our day-to-day
operations.
Communicate with You. We use your personal information to communicate with
you, including responding to your questions and requests. We may also use your personal
information to send you communications to request information, seek your feedback, or provide
you with administrative information, such as changes to our terms, conditions, and policies.
Respond to your Requests to Exercise your Rights. We use your personal
information to respond to your requests to exercise your rights over your personal
information.
Send You Promotional and Marketing Materials. We use your personal
information to send you newsletters and other promotional communications, including
information about Cal AI’s new offerings, features, offers, events, webinars, and other
information.
Targeted Advertising and Cross-Device Tracking.
Targeted Advertising. We may engage in targeted advertising. This means
that you may see advertisements that are targeted and personalized to you on the Services
and/or you may see advertisements for Cal AI on third-party services based on information
that we have collected from and about you. We and our third-party partners may use
Tracking Technologies to collect information about you. This includes your device’s IP
address, online identifiers (e.g., cookie ID, mobile advertising ID, etc.), and activity
information for such purposes. For example, our partners may use the fact that you visited
our website to deliver advertisements to you on non-Cal AI websites or they may use the
fact that you used our mobile app to deliver advertisements to you in other mobile apps.
Additionally, we and our partners may use the information collected to determine whether
our interest-based advertising activities resulted in you engaging in other activities on
the Services, receiving and interacting with our advertisements, or otherwise engaging
with us.
Cross-Device Tracking. We and our third-party partners may use the
information we collect to help us identify other devices that you use (e.g., a mobile
phone, tablet, computer, etc.). This means that your online behavior on your current
browser or device and your device’s location may be combined with information collected
from your other browsers or devices. Upon making an inference that a device is in use by
you, our partners may use this information to deliver an advertisement on the device, to
limit the number of times you see an advertisement across your devices, and to help
measure the effectiveness of our campaigns across devices.
Analyze usage of our Services, Ad Performance, and Research.
Analyze performance of ads. We engage third-party analytics providers to
help us analyze traffic to evaluate usage of the Services and to understand the
performance of our advertisements. These third parties may use Tracking Technologies on
the Services to collect information for such purposes.
Research. We use your personal information to administer surveys and
questionnaires that help us better understand how Cal AI users access and use the
Services and for other research and analytics purposes, including to measure the
effectiveness of the Services and the effectiveness of our marketing and advertising
efforts.
Enhance and Personalize our Services. We use your personal information to
improve and enhance our Services, including through the use of various technologies (e.g.,
business intelligence tools, machine learning systems, and artificial intelligence),
personalize content and features to your interests and goals (e.g., providing suggestions,
reporting and analytics, meal plans, and recommendations), and test out new features and
updates to our Services.
Plan and Manage Events. We use your personal information to assist with event
planning activities, such as event registration and attendance and connecting you with other
event attendees. We may also use your personal information to facilitate special events,
sweepstakes, contests, and promotions, which have their own specific participation rules.
Maintain Security and Protect Rights. We use your personal information to
help monitor and maintain the security of the Services and our business operations.
Additionally, we use your personal information to prevent and detect fraud, unauthorized
activities and access, and other misuse of the Services to protect you, our business, and
others from unauthorized transactions and other unlawful or unsafe activity.
Satisfy Our Legal Obligations. We use your personal information to comply
with applicable legal and regulatory obligations and respond to legally valid requests and
communications from law enforcement authorities to the extent required by applicable law.
Manage pre-litigation or litigation matters. We use your personal information
to defend our rights and interests in the event of pre-litigation or litigation.
Carry Out Internal Operations. We use your personal information to conduct
financial, tax, and accounting audits and assessments of our operations, including our
privacy, security, and financial controls. We also use your personal information to administer
our business, accounting, compliance, recordkeeping, and legal functions and for related risk
and compliance purposes. We may also use your personal information to help maintain
appropriate business records and enforce our policies and procedures.
Carry Out Sales and Business Transactions. We may use your personal
information in connection with the evaluation, negotiation, and/or completion of a business
transaction (e.g., a merger, divestiture, restructuring, acquisition, reorganization,
dissolution, or other sale or transfer of some or all of our assets), whether as a going
concern or as part of any bankruptcy, liquidation, or similar proceeding, in which personal
information held by us is among the assets transferred or is otherwise relevant to the
evaluation, negotiation, or completion of the transaction.
How We Disclose Personal Information
We disclose personal information to the categories of recipients described below:
Our Business Partners. We may partner with other businesses to offer the
Services and disclose your personal information to those business partners as necessary or
appropriate for the purposes listed in this Policy.
Our Service Providers. We may disclose your personal information to third
parties that provide business, professional, or technical support services to us and/or
perform functions on our behalf to provide the Services. The services provided by these
parties may include IT and website hosting, payment processing, market research, customer
support (including our Support Center chatbot virtual agent), data storage, data analytics,
auditing, and consulting and legal services.
Other Cal AI Users. We may disclose your personal information to other Cal AI
users in the context of specific features that are social in nature as part of the Services.
For example, we will display any personal information that you post or make available using
the Services’ public-facing or interactive features, Groups, or discussion blogs.
Our Marketing and Advertising Partners. We may disclose your personal
information, including device and browser information and activity and usage information, to
our marketing and advertising partners, including social media platforms, third-party
advertising networks, and other parties that assist us in serving, measuring the performance
of, and optimizing our advertising campaigns.
Our Analytics Providers. We may disclose your personal information, including
device and browser information and activity and usage information, to parties that assist us
in performing analytics and help us measure the effectiveness of the Services and our online
and offline marketing and advertising efforts.
Our Research Partners. We may disclose your personal information to our
research partners, including those that perform surveys or research projects in partnership
with us or on our behalf.
Relevant Third Parties in Connection with Business Transactions or
Reorganizations. If we or our affiliates are or may be acquired by, merged with, or
invested in by another company, or if any of our assets are or may be transferred to another
company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may
disclose or transfer your personal information to the other company in accordance with
applicable laws. We may also disclose certain personal information as necessary prior to the
completion of such a transaction or other corporate transaction, such as a financing or
restructuring, to lenders, auditors, and third-party advisors, including attorneys and
consultants.
Law Enforcement and Regulatory Authorities. We may disclose your personal
information to comply with applicable legal and regulatory obligations and respond to legally
valid requests and communications from law enforcement authorities to the extent required by
applicable law.
Other Parties. We may disclose your personal information to other parties at
your direction or with your consent or as it may be justified under applicable law. If you are
the winner of a sweepstakes or other contest, we may disclose your personal information to
anyone who is entitled to request a winner’s list. Finally, we can disclose your personal
information to other parties as necessary or appropriate to: (i) comply with applicable law;
(ii) protect the Services, our rights and property, or the rights, property, privacy, or
safety of others; (iii) prevent, detect, investigate, and respond to fraud, unauthorized
activities and access, illegal activities, or misuse of the Services; (iv) enforce, detect,
investigate, and take action in response to violations of the Cal AI Terms; and/or (v) allow
us to pursue available remedies or limit damages that we may sustain.
Managing your Marketing and Personalized Advertising Preferences
You have the ability to manage your Cal AI account and your preferences as described below.
Marketing Communications
We may send you periodic marketing and promotional emails or other similar communications, and
we will obtain your consent to do so, where required by law. If you no longer wish to receive
marketing and promotional communications from us, you may:
Change your email preferences in your account settings; or
Unsubscribe from these communications by following the “unsubscribe” instructions included in
those communications.
Cookie Preferences
Depending on the country where you reside, you have choices with respect to cookies. For
example, by modifying your browser preferences, you have the choice to accept all cookies, to be
notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies,
some of the Services’ features may not work properly. You can manage your cookie preferences via
.
These preferences are reflected at a browser level — if you use more than one browser you will
need to choose your preferences (e.g., opt out) in each browser. If you use the same browser on
multiple devices, you will also need to choose your preferences on each device.
Personalized Advertising Preferences
We may engage in targeted advertising. This means that you may see advertisements that are
targeted and personalized to you on the Services and/or you may see advertisements for Cal AI on
third-party services based on information that we have collected from and about you. If you’d
like to consent, opt in, or opt out of such advertising through our app, you can do so by
visiting your profile settings.
These preferences are currently reflected at a browser or device level — if you use more than
one browser you will need to choose your preferences (e.g., opt out) in each browser. If you use
multiple devices, you will also need to choose your preferences on each device (for example,
opting out both at the Cookie Preferences link and in the App).
International Transfers of Personal Information
Cal AI is headquartered in the United States and has service providers in the United States and
throughout the world. As a result, your personal information may be transferred to the United
States and other countries or regions with data protection and privacy laws that differ from
those in your country of residence.
When we transfer your personal information outside of your country of residence, we do so in
accordance with applicable law and take appropriate steps to ensure your information is
protected. However, please note that while outside of the jurisdiction in which you reside, your
personal information will be subject to applicable local laws, which might permit foreign
governments, courts, law enforcement, or regulatory agencies to access your information in
certain circumstances.
By using the Services and/or sharing your personal information with Cal AI, you are informed
that your personal information may be transferred to countries outside of your country of
residence.
User-Generated Content
We may offer public-facing interactive features, community forums, or discussion blogs on the
Services that enable you to share information (e.g., your achievements, reviews, testimonials,
etc.). Any information you post to any public-facing section of the Services may be publicly
viewable. By posting to such interactive features you acknowledge and agree that you have no
expectation of privacy or confidentiality in the content you submit through such features,
whether or not it contains your personal information. For more information about how this
information is used, see our Terms of Service.
How We Protect Your Information
We maintain reasonable technical, organizational, and administrative safeguards designed to
protect the personal information under our control from loss, misuse, and unauthorized access,
disclosure, alteration, and destruction. Please be aware that despite our efforts, no
information security measures can guarantee security.
How We Retain Your Information
We will retain your personal information as long as necessary to fulfill the purposes outlined
in this Policy (including to satisfy our legal or reporting requirements), unless a longer
retention period is required or allowed under law. To determine the appropriate retention period
for personal information, we consider the amount, nature, and sensitivity of the personal
information; the potential risk of harm from unauthorized use or disclosure of the personal
information; the purposes for which we use the personal information; whether we can achieve the
purposes through other means; and the applicable legal requirements.
If we de-identify information, we will maintain and use the information in de-identified form
and not attempt to re-identify the information except as required or permitted by law.
Contact Us
If you have any questions or concerns regarding this Policy or our privacy practices, you may
contact us at privacy@calai.app, or write us at:
Cal AI, Inc.
ATTN: Cal AI, Inc. Privacy/Legal
100 Congress Avenue, Suite 400
Austin, TX 78701
Your Privacy Rights
Depending on where you live, the laws of your country, state, or province may have certain
privacy rights over how your personal information is collected, stored, used, and shared,
including:
Right to Access and Data Portability. The right to confirm whether we are
processing your personal information, who we share it with, and to access or obtain a copy of
your personal information in a portable and, to the extent technically feasible, readily
usable format.
Right to Deletion. The right to request that we delete your personal
information (subject to certain exceptions prescribed by applicable law).
Right to Correction. The right to request that we correct inaccuracies in
your personal information, taking into account the nature of the information and purpose(s)
for which we are processing it.
Right to limit or opt out of certain types of processing. This includes:
the “sale” of your personal information. Please note that while Cal AI does not expressly
“sell” information to others, certain uses of Functional Cookies and/or Targeted
Advertising Cookies on our website to collect, use, and disclose information may
constitute “sales” or “sharing” of personal information or the use of personal information
for “targeted advertising” purposes under applicable privacy laws;
the processing of your personal information for “profiling” and “targeted advertising”
purposes; and
certain forms of “profiling” (in each case, as these terms are defined in applicable law).
Right to opt in to processing of sensitive information. Some states offer
their residents the right to opt in to the use of sensitive information. In this scenario,
this means we cannot use sensitive information (outside of the provision of our Services)
without your consent.
Right against discrimination. We will not discriminate against you if you
decide to exercise your legal rights.
Right to appeal decisions. You may have a right to appeal a decision on a
privacy rights request. To appeal such a decision, please submit your request to
privacy@calai.app with “APPEAL” included in the subject
line.
How do I exercise my rights?
You can exercise your privacy rights by submitting your request to
privacy@calai.app. In your communication, please state
the request you would like to make and rights you wish to exercise.
Where legally permitted, you may submit requests through an authorized agent or representative
at privacy@calai.app. To process these requests, we will
need to verify the identity of the agent and that you have authorized them to act on your
behalf.
Questions. You can also contact us at
privacy@calai.app if you have any inquiries or complaints
regarding our processing of your personal information.
Additional Information for Certain Jurisdictions
Residents of certain jurisdictions have additional rights under applicable laws, including
residents of certain states within the United States (e.g., California and Washington), the
European Economic Area (EEA), Switzerland, the United Kingdom (UK), and Canada.
United States — California
California Shine the Light. Residents of the State of California have the right
to request information from Cal AI regarding other companies to whom the company has disclosed
certain categories of information during the preceding year for the other companies’ direct
marketing purposes. To make such a request, please contact us at
privacy@calai.app.
California Consumer Privacy Act. The California Consumer Privacy Act (“CCPA”)
(as amended by the California Privacy Rights Act) provides California residents with the right
to receive certain disclosures regarding the collection, use, and sharing of “Personal
Information,” as well as the right to know/access, delete, and limit sharing of Personal
Information. “Personal Information” means “information that identifies, relates to, describes,
is reasonably capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or household.” Certain information we collect may be
exempt from the CCPA because it is considered public information (e.g., it is made available by
a government entity) or covered by a specific federal privacy law.
Right to notice at collection regarding the categories of Personal Information collected
You have the right to receive notice of the categories of Personal Information we collect, and
the purposes for which those categories of Personal Information will be used.
Category of Personal Information
Required Information
Personal Identifiers
We may collect names, email addresses, phone numbers, postal addresses, account names,
online identifiers, IP addresses, and other similar identifiers.
Source:
Our users (directly and automatically)
Third parties
Business partners;
Service providers;
Other Cal AI users;
Analytics providers; and
Research partners.
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Business partners
Service providers
Other Cal AI users
Analytics providers
Research partners
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Protected classification characteristics
We may collect protected classification characteristics under California law or federal
law, including age (over 40) and sex/gender expression.
Source:
Our users (directly)
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Other Cal AI users
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold: N/A.
Commercial Information
We may collect records of products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies.
Source:
Our users (directly and automatically)
Third parties
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Analytics providers
Research partners
Marketing and advertising partners (including social media platforms and third-party advertising networks)
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Internet or other electronic network activity information
This may include browsing history, search history, and information regarding interactions
with the Services and advertisements.
Source:
Our users (directly and automatically)
Third parties
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Analytics providers
Research partners
Marketing and advertising partners (including social media platforms and third-party advertising networks)
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Geolocation data
Such as IP address, country in which you reside, and zip code. Cal AI does not collect
specific geolocation information.
Source:
Our users (directly and automatically)
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Analytics providers
Research partners
Marketing and advertising partners (including social media platforms and third-party advertising networks)
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Audio, electronic, visual, or similar information
This may include audio input logging, profile images/photos, and progress photos.
Source:
Our users (directly and automatically)
Third parties
Service providers
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold: N/A.
Inferences drawn from other personal information
This may include inferences drawn from any of the information in the above-listed
categories reflecting individuals’ preferences, characteristics, behaviors, attitudes,
abilities, and aptitudes.
Source:
Our users (directly and automatically)
Business partners
Service providers
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Sensitive Personal Information
This may include Health and Nutrition Data you input about your dietary habits and
activities you engage in.
Source:
Our users
Business partners
Service providers
Purpose of Collection and Use: Business purpose.
Categories of Parties with whom the Information may be Shared: This
information may be shared with the following third parties for business purposes:
Service providers
Has this information been shared with these parties within the last 12
months? Yes.
Categories of Parties to whom the Information may be Sold:
While Cal AI does not expressly “sell” information to others, certain uses of Functional
Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose
information may constitute “sales” or “sharing” of personal information or the use of
personal information for “targeted advertising” purposes under applicable privacy laws.
Right to know about personal information collected, disclosed, shared, or sold.
You have the right to request that we disclose to you the personal information we collect, use,
disclose, share, or sell.
Right to know/access information. You have the right to request access to
Personal Information collected about you and information regarding the source of that
information, the purposes for which we collect it, and the third parties and service providers
with whom we share it.
Right to request deletion of information. You have the right to request in
certain circumstances that we delete any personal information that we have collected directly
from you.
Right to information regarding participation in data sharing for financial
incentives. You have the right to be free from discrimination based on your exercise
of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer
to share certain pieces of information with us. Participation in these incentives is
voluntary, and you may opt out of the data sharing at any time.
Right to Opt Out of sale of Personal Information to third parties. While Cal
AI does not expressly “sell” information to others, certain uses of Functional Cookies and/or
Targeted Advertising Cookies on our website to collect, use, and disclose information may
constitute “sales” or “sharing” of personal information or the use of personal information for
“targeted advertising” purposes under applicable privacy laws.
Right to Opt Out of Sharing Personal Information for Cross-Contextual Behavioral
Advertising. You have the right to opt out of sharing your personal information with
third parties that generate a profile about you for marketing purposes.
Right to Restrict Use of Sensitive Personal Information. You have the right
to request that we restrict our use of certain pieces of personal information that are
considered sensitive under California law — such as information about your race, ethnicity,
religion, and philosophical beliefs, financial information to the extent such would enable
access to your account, biometric information, and health information.
Right to Correct/Rectify Inaccurate Information. You have the right to
correct inaccurate personal information that we hold about you under certain circumstances. We
may need to verify the validity and scope of the request as well as the scope and purpose of
maintaining it.
Right to Non-Discrimination. You have the right to be free from
discrimination based on your exercise of your CCPA rights. We may run promotions from time to
time wherein we incentivize a consumer to share certain pieces of information with us.
Participation in these incentives is voluntary, and we will provide more information when we
ask you to participate.
How to submit a request
You can exercise your privacy rights by submitting your request to
privacy@calai.app. In your communication, please state
the request you would like to make and rights you wish to exercise.
Where legally permitted, you may submit requests through an authorized agent or representative
at privacy@calai.app. To process these requests, we will
need to verify the identity of the agent and that you have authorized them to act on your
behalf.
United States — Washington
The Washington My Health My Data Act requires certain disclosures to Washington residents
regarding the use of “consumer health data.” Those disclosures and related privacy rights can be
found in our Washington Consumer Health Data Privacy Policy.
European Economic Area (EEA), Switzerland, and United Kingdom (UK) Residents
If you reside in the EEA and are under 18 years of age, you should not use our Services. If we
become aware that an individual under 18 years of age may have provided us with personal
information, we will investigate and, if applicable, take steps to remove and delete the data
and delete that individual’s account.
Data controller Information. For the purposes of applicable data protection
laws, Cal AI, Inc. is the controller of the personal information you provide us.
How to contact Cal AI, Inc.
Postal mail: 100 Congress Avenue, Suite 400 — Austin, TX 78701.
Through our EEA Representative, DataRep, Cal AI has appointed DataRep as their Data Protection
Representative in the European Union and Switzerland so that you can contact them directly in
your home country. DataRep has locations in each of the 27 EU countries, the UK, and Norway &
Iceland in the European Economic Area (EEA) and Switzerland, so that Cal AI’s customers can
always raise the questions they want with them.
If you wish to raise a question to Cal AI, or otherwise exercise your rights in respect of your
personal information, you may do so by:
If you have other questions regarding Cal AI’s privacy practices, you may contact our Data
Protection Officer by email at privacy@calai.app or by
postal mail at the address above.
Your rights
You have the right to:
Request access to your personal information, which enables you to receive a
copy of the personal information we hold about you.
Request correction or rectification of the personal information we hold about
you, which enables you to correct inaccurate or incomplete personal information about you.
Request to erase or delete your personal information that we hold. There may
be certain circumstances that prevent us from fully deleting your information at the time of
the request due to legal or regulatory reasons. If this is the case, we will advise of these
circumstances in response to your request.
Request to limit or object to processing your personal information where we
(or a third party) have a legitimate interest or where we are processing your personal
information for direct marketing purposes or using automated processes. In some cases, we will
not be able to comply with your request if we have compelling legitimate grounds for the
continued processing which override your interests, or for the establishment, exercise, or
defence of legal claims.
Request review of automated decisions made solely on the basis of automated
processing of personal information that affect your interests.
Request to transfer your data in a portable format. You can ask us to provide
you or a third party with your personal information in a portable (machine readable) format
where we have collected your consent or otherwise perform obligations due to a contractual
necessity.
Right to object to marketing. You may object at any time to your personal
information being processed for direct marketing including profiling.
Withdrawal of consent. You may withdraw your consent at any time to any
processing of personal information based on your consent, where applicable, without
compromising the lawfulness of the processing based on consent carried out prior to such
withdrawal.
Digital legacy (only if you are a French resident). If you are located in
France, you have the right to set out instructions (general or specific) about what happens to
your personal information after your death.
How to exercise your rights
Please contact us at privacy@calai.app if you wish to
exercise any of your rights. You can also contact us through our EEA Representative or DPO if
you have any questions or complaints regarding the processing of your personal information.
Regarding our use of tracking technologies for targeted advertising and personalization, you may
revise your choices by visiting
on our website or by visiting “Manage your Personalization Preferences” in the App.
How to lodge a complaint
If you consider that the processing of your personal information violates applicable data
protection laws, you also have the right to lodge a complaint about our processing of your
personal information or our handling of your rights request with the appropriate data protection
regulator, i.e., the data protection regulator located where you reside, at your place of work
or at the place of the alleged infringement (see the links below).
Applicable data protection laws require us to set out the lawful basis that we rely on to
collect and process personal information. Here is a list of the lawful basis that we rely on for
each of our processing activities (please note this supplements the descriptions found in the
How We Use Personal Information section above).
Processing Activity
Lawful Basis for Processing Personal Information
Provide and Manage the Services
Consent (for processing of sensitive data, such as health data). Performance of our
contract with you and otherwise provide you with our Services.
Conduct Research and Analytics
Legitimate Interests (specifically our interests in improving the Services to expand our
business and increase our revenue).
Communicate with You
Performance of our contract with you and otherwise provide you with our Services.
Send You Promotional and Marketing Materials
Consent (where required by law). Legitimate Interests when consent is not required by law
(specifically our interests in marketing features and products that may interest you,
expanding our business, and increasing our revenue).
Enhance and Personalize the Services
Consent.
Engage in Interest-Based Advertising
Consent.
Plan and Manage Events
Legitimate Interests (specifically our interests in managing our relationship with you,
expanding our business, and increasing our revenue).
Maintain Security and Protect Rights
Legitimate Interests (specifically our interests in conducting our business in a lawful
manner and protecting our rights and interests as well as those of our stakeholders and
society at large).
Respond to requests and communications from law enforcement authorities or other government officials
Compliance with a Legal Obligation.
Respond to your requests to exercise your rights
Compliance with a Legal Obligation.
Manage pre-litigation or litigation matters
Legitimate Interests (specifically our interests in conducting our business in a lawful
manner and protecting our rights and interests as well as those of our stakeholders and
society at large).
Carry Out Internal Operations
Legitimate Interests (specifically our interests in conducting and managing our business
to improve our performance metrics and maintain profitability).
Carry Out Sales and Business Transactions
Legitimate Interests (specifically our interests in organizing our business efficiently).
Information Retention
We will retain your personal information for as long as is necessary for the purposes set out in
this Policy, including to comply with our legal obligations (for example, if we are required to
retain your data to comply with applicable law or court orders), resolve disputes, and enforce
our legal agreements and policies.
International Transfers of Personal Information
Your personal information may be transferred to countries outside of the EEA, Switzerland, and
the UK, including the United States, to companies that are not certified under the EU-US Data
Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data
Privacy Framework. We have put in place adequate measures, and where necessary, we have
implemented additional contractual, organizational, and technical measures to protect your
personal information. You can obtain a copy of these measures by contacting our DPO or EEA
Representative.
Canada
Processing of Personal Information. You are generally not obliged to provide
your personal information, but we may be unable to provide certain services to you if you refuse
to disclose certain personal information.
Privacy Rights and Requests
Consent to process your personal information. Unless otherwise allowed by the
laws applicable in your province or territory of residence, we will only collect, use, or
communicate your personal information with your consent (which may be express or implied). You
are generally not obliged to provide your personal information, but we may be unable to
provide certain services to you if you refuse to disclose certain personal information.
Right to access and correct your information. You have the right to access
the personal information we hold about you and correct or amend your information as
appropriate. If you have unresolved concerns regarding our handling of your personal
information, you have the right to complain to the relevant data protection authority.
Quebec residents
Right of Data Portability. The right to receive your personal information in
a structured, commonly-used, and machine-readable format and to request that we transmit your
personal information to another organization.
Right to De-indexation. The right to request, in certain circumstances, that
we cease disseminating your personal information or to de-index any hyperlink that allows
access to your personal information by technological means, if such dissemination contravenes
applicable law or a court.
To exercise your rights, please submit your request to
privacy@calai.app.
