Privacy Policy

Elwin AI · Effective date: 27 February 2026

1. Who we are

Elwin AI is operated by Lead One Limited, a company registered in England and Wales (company number: 12967668). Our registered address is Pride Park, Derby, UK.

2. What data we collect

When you use the Elwin bot (@elwin_a_bot) or visit hielwin.com, we collect:

Account data — Telegram user ID, display name, timezone, age, height, weight
Food diary data — meal descriptions, AI-estimated nutrition values, photos, water and mood notes
Weight data — weight entries over time
Subscription data — Stripe customer and subscription IDs, billing events
Usage data — message timestamps and interaction logs
Feedback — bug reports, feature requests, general feedback

3. Lawful basis for processing

We process your data under the following legal bases (UK GDPR Article 6):

Data type	Lawful basis
Account and diary data	Contract — necessary to provide the service
Subscription and billing data	Contract and legal obligation (financial records)
Photos	Contract — necessary to provide AI food logging
Feedback	Legitimate interests — to improve the product
Usage data	Legitimate interests — to ensure correct and secure operation

4. How we use your data

Provide the food diary and nutrition tracking service
Calculate and track daily nutrition targets
Generate daily and weekly reports
Process and manage your subscription via Stripe
Review feedback to improve the product
Notify you of subscription events

We do not sell your data to third parties. We do not use your data for advertising.

5. AI processing

Food descriptions and photos you send are processed by Anthropic's Claude AI to estimate nutritional content. Photos are not stored by Anthropic — they are processed in real time and only the resulting nutrition data is stored in our database.

Anthropic privacy policy →

6. Who we share data with

Recipient	Location	Purpose
Supabase	USA (SCCs apply)	Database and file storage
Vercel	USA (SCCs apply)	Hosting and deployment
Stripe	USA (SCCs apply)	Payment processing
Anthropic	USA (SCCs apply)	AI food logging
Telegram	UAE/USA	Message delivery

Where data is transferred outside the UK, we rely on Standard Contractual Clauses (SCCs) to ensure an equivalent level of protection.

Club owners: If you join a nutrition club, the club owner can view your nutrition logs. You will be asked for explicit consent first and can revoke it at any time by typing "leave club" in the bot.

7. Data retention

Data	Retention period
Food diary logs	Duration of active account
Photos	12 months
Reports	12 months
Account data	30 days after account closure
Subscription/billing data	7 years (UK tax law)
Feedback	2 years

8. Your rights under UK GDPR

Access — request a copy of your personal data
Rectification — ask us to correct inaccurate data
Erasure — ask us to delete your account and data
Portability — receive your data in a machine-readable format
Objection — object to processing based on legitimate interests
Restriction — request we limit processing in certain circumstances
Withdraw consent — where processing is based on consent, withdraw at any time

To exercise any right, email support@hielwin.com or type "delete my account" in the bot. We will respond within 30 days.

You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

9. Cookies

hielwin.com does not use tracking or advertising cookies. Strictly necessary cookies may be set by Stripe during the subscription checkout process.

10. Children

Elwin is not intended for use by anyone under the age of 16. We do not knowingly collect data from children. Contact support@hielwin.com if you believe a child has provided us with data.

11. Changes to this policy

We will notify you via the bot if we make material changes to this policy. The effective date at the top of this page reflects the latest version.

12. Contact

Lead One Limited
Pride Park, Derby, UK
Company number: 12967668
support@hielwin.com