Privacy Policy
This is how Tulbrain collects, uses and protects your data.
Effective date: October 19, 2026
1. Who we are.
NETMIND CLOUD LLC, 1621 Central Ave, Cheyenne, Wyoming 82001, USA (“we”), operates the Tulbrain Service. This policy explains what personal data we collect, why, and your rights. Contact: hello@netmindcloud.com.
2. Data we collect.
(a) Account data: when you sign in with Apple we receive an email address — either your own, or a private relay address that Apple creates for you and forwards to your inbox; you can turn that relay address off at any time in your Apple account settings, and if you do, we will no longer be able to reach you at it. If Apple gives us no address, the app asks you for one. When you sign in with Google we receive your email address, and on Android also the name and profile picture on your Google account; these are stored as part of your sign-in record and are never shown to other users. If you choose to set an email address and a password from your profile settings, that password goes over an encrypted connection to Google Firebase, the authentication service we use (see section 5), and never reaches our servers. (b) Referral data: the account is given a referral code you can share, and we store the code of whoever referred you, if any. (c) Learning data: your progress (lessons completed, exercise results, practice statistics), your courses and enrolments, your energy balance and, for 90 days, its movements (what you used, the daily gift and the ads you watched to recharge), your plan, the country of your app store (to offer the plans available in your country), and your preferences (app language, course, appearance). In addition, we keep your progress in the games (level, best score and games played) and, for 90 days, the details of each game (game, level, score, duration and date), which we also use in aggregate to adjust the difficulty. (d) Purchase data: if you buy a subscription through an app store, we receive from that store, and keep with your account, what we need to give you access: the plan and billing period, the store’s reference for the purchase, whether the subscription is active and set to renew, and when the current period ends. If you buy an energy pack, we keep with your account the pack, the store’s reference for that purchase (and, on Google Play, the purchase identifier the store gives us to confirm it and to be notified if it refunds it), the purchase date, the energy credited, the energy you have left unused and, if the store refunds it, the energy deducted and the date. We keep this while your account exists, and it is deleted with it. We never receive your card or other payment details — the store handles the payment. (e) Advertising data: if you choose to watch an ad — for example, to recharge your energy — the app loads Google AdMob, which collects from your device your IP address (used to estimate your general location; the app has no access to your device’s precise location), how you interact with the ad, technical and performance information about the app and the ad, and device identifiers other than the advertising ID (the Android advertising ID, or the IDFA on iPhone, which the app never asks for). Google receives this data directly, as an independent controller (see section 6). (f) Notice records: when we notify you in the app of a change to our Terms or to this policy, we record the version and when you closed the notice, as proof that you were informed. This record is deleted with your account. (g) Guest data: if you use the app without an account, we keep an anonymous, temporary ID and your energy count and your progress in the games for up to 36 hours, then delete them. Apart from the advertising described in (e), we do not collect your device model or your app version, and we do not collect sensitive categories of data, precise location, or contacts. Public Speaking can record your rehearsal (your voice and, if you choose, video) only when you turn recording on. Your recordings, the nerves ratings you give yourself and your review progress stay on your device: they are never uploaded to us or to anyone else, and they are excluded from device backups. Deleting a speech deletes its recordings; deleting your account from the app on that device, or uninstalling the app, deletes all of it.
3. How we use data.
To provide and sync the Service across your devices; to save and display your learning progress; to manage subscriptions; to maintain security; to improve the Service using aggregated, non-identifying statistics; and, only if you choose to watch one, to show you a rewarded ad.
4. Legal bases.
Performance of the contract (providing the Service), your consent where required (in the European Economic Area and Switzerland we ask for it before any ad is loaded, and you can change your choice at any time in the app’s Settings), and our legitimate interest in securing and improving the Service and, if you do not consent, in showing you the limited ads you ask for.
5. Storage and processors.
Data is stored with reputable cloud providers (currently Google Firebase / Google Cloud Platform, located in the United States), acting as processors under their own safeguards. The emails we send (such as the waitlist confirmation) go through Google Workspace, which also acts as a processor. Using the Service from other countries implies international transfer of your data to those servers.
6. Sharing and advertising.
We do not sell personal data. The app shows rewarded ads: you choose when to watch one, and we never interrupt a lesson with an ad. The ads are served by Google AdMob, which acts as an independent controller for the advertising data described in section 2(e); its use of that data is governed by Google’s own privacy policy (https://policies.google.com/privacy). We do not show personalised ads to anyone, every ad is limited by a content rating that matches the app’s rating in each store, we block sensitive ad categories such as gambling, alcohol and get-rich-quick schemes, and we do not share your learning data with advertisers. If you do not consent, you may still see limited ads that are not personalised and do not use advertising identifiers; they may use storage on your device only to detect fraud. We count, without linking it to you, how many times ads are shown or tapped, so we can check our ad income. Deleting your Tulbrain account deletes the data we hold, except as described in section 7; data that Google holds as an independent controller is governed by Google’s policy.
Apart from advertising, we share data only with the processors in section 5, with app stores for payment management, and where required by law.
7. Retention.
We keep your data while your account is active. If you do not open the app for 12 months, we delete your account and everything in it. We send a reminder to the email address on your account 30 days before that happens, and opening the app at any point starts the 12 months over. When you ask us to delete your account, we act without undue delay and in any event within one month; once your request is verified and executed, your personal data is removed immediately. Four exceptions: a minimal record that the account was deleted — an internal account identifier and the date — kept as proof that we carried out your request, and used for nothing else; records we are legally required to keep, for as long as the applicable law requires; residual copies in routine encrypted backups, which remain until those backups expire and are never used to restore deleted accounts; and, if you delete your account while a Google Play subscription is active and we cannot cancel it automatically, the store’s reference for that purchase — without your account or email — kept only so that we can cancel it by hand, and removed once it is cancelled and within 30 days at the most. If you subscribed through the App Store, deleting your account does not cancel the subscription: only you can cancel it, in your Apple Account settings. Aggregated statistics that cannot be linked back to you contain no personal data and may be kept.
8. Your rights.
Depending on your jurisdiction, you may request access, rectification, deletion, portability, or restriction of your data. Write to hello@netmindcloud.com and we will respond without undue delay and in any event within one month. If you are in the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with your local data protection authority.
9. Age.
The Service is intended for people aged 18 and over. We do not knowingly create accounts for anyone under 18, and we do not ask for or store a date of birth. If you believe a person under 18 has an account, write to hello@netmindcloud.com and we will delete it.
10. Changes.
We may update this policy; material changes will be notified in the app.
11. Waitlist and launch updates.
The waitlist is closed to new sign-ups; this section covers the addresses already on it. If you joined it, we collected your email address, with your consent, to send you updates about Tulbrain’s launch and founding-member campaign. We also use the language version of the page you signed up from, so we can write to you in that language. We use double opt-in: when you submit the form we store your address and send you a confirmation email, and we only add you to the list — and only ever email you again — once you confirm. If you do not confirm, your address is deleted when the confirmation link expires, seven days after you sign up. The list is stored with the processors described in section 5, is used only for these updates, and is never sold or shared for third-party marketing. Every update we send to the list includes an unsubscribe link, and unsubscribing deletes your address. You can also request deletion at any time by writing to hello@netmindcloud.com. Whenever your address is deleted, residual copies may remain in routine encrypted backups until those backups expire — up to about two weeks. Besides your address we keep only the technical record of your sign-up and confirmation — the dates, and a one-way hash of the links we email you — which is how we can show you gave consent. We keep your address while the launch and founding-member campaign is running, and for no more than 24 months after you confirm; after that we delete it, even if you never unsubscribed.
12. Our websites.
This policy also covers our websites: netmindcloud.com (our company site), tulbrain.com (the product site) and tulbrain.us (the launch page). These sites have no user accounts, no analytics and no advertising, and they set no cookies of their own. The only exception is the video player embedded on some pages, which runs in no-cookie mode and stores nothing unless you press play. When you submit a form on our sites, we also process your IP address ourselves, to limit how many sign-ups can come from one connection and to stop automated abuse. We do not store the address: we store a keyed one-way code derived from it, under a secret key that changes every day, in a separate record that holds no email address and is deleted within three days. Our hosting provider (see section 5) separately keeps standard server logs, including IP addresses, for security and abuse prevention. Where a website form collects anything, it says so at the point of collection — see section 11 for the waitlist.