Privacy Policy

• Account data – your name and email address when you create an account.
• Learning content you provide – the learning material you choose to upload or paste, and the personalised study content we generate from it for you.
• Usage data – how you use the Service (e.g. study sessions and your learning progress).
• Technical data – device, browser, and log information needed to run and secure the Service.

We use your data to: provide and operate the Service (generate your personalised study content and track your learning progress); maintain and improve the Service; communicate with you about your account and reminders you opt into; and keep the Service secure and prevent abuse.

We process your data on the basis of: performance of our contract with you (to provide the Service); your consent (e.g. for push/email reminders, where applicable); and our legitimate interests in operating, securing, and improving the Service.

To create your personalised study content, the learning material you upload is processed by trusted third-party AI service providers acting on our behalf, under appropriate data-processing terms. This content is processed solely to provide the Service to you and is not used by us to train AI models.

If you share a quiz, a copy of it becomes readable by anyone who has the link. This happens only when you choose to share, and you can revoke a link at any time.

What the shared page contains: the quiz title, the questions and answer options as they were when you shared them, and the language they are written in.

What it never contains: your name, email address, or profile picture – a shared quiz does not say who shared it; the photos, files, or text you uploaded; your learning progress, scores, streaks, or any other quiz or account data. The shared copy is separate from your account data, so nothing else can be reached from the link.

Anything you typed yourself becomes public. If a title or a question contains personal information – yours or someone else's – sharing publishes it. Please do not share quizzes containing personal data.

People who open a shared link: we record that the link was opened or completed, and limited technical data (such as IP address and device information) to prevent abuse and misuse. The person who shared sees counts only – never who opened or took the quiz. Anyone can take a shared quiz without an account.

Legal bases: publishing the quiz is performance of our contract with you, at your request; abuse prevention and the handling of reports rest on our legitimate interest in keeping the Service lawful and safe. If someone reports a shared quiz, we process the report and the reporter's contact details in order to review it.

Deletion: revoking a link, deleting the underlying material, or deleting your account removes the shared copy. Reports and moderation records may be kept for as long as needed to handle them.

Your rights. The rights set out in section 10 below – access, correction, deletion, restriction, objection, data portability, withdrawal of consent, and complaint to the Austrian Datenschutzbehörde – apply to shared-quiz data in the same way as to the rest of your account data.

If you apply for the 50% professional discount (Expert), to prove your eligibility you upload one of the following:

• a degree in Psychology, Psychiatry, or Neurology;
• a confirmation that you are currently studying one of those; or
• your certificate in ADHD or neurodivergency coaching.

Review: the uploaded document is reviewed by a human – no automated analysis, no profiling. We reach one of three outcomes: approved, declined, or we need more information – in that case we tell you what's missing and ask you to upload a new document.

Deletion: the file is deleted as soon as we reach any of these three outcomes, including when we ask for more information. If we ask for more information, the new document you upload goes through the same review and is deleted under the same rule when the next outcome is reached.

Which information we keep: which of the three categories it was, the decision, the date, an internal note, and – for the student route – a date five years out when we ask once for confirmation of completion. If approved, we also keep the subscription the discount is attached to. This is kept for as long as the discount applies to your subscription.

Confirming completion after five years. If you received the Expert discount because you were studying, five years later we ask you once, on your subscription page, to upload a document showing that you finished your degree (a degree certificate) or your coach certificate. This upload uses the same consent and the same private storage as your original application (Art. 6(1)(a) GDPR).

If you upload the document by the date in our request, your discount keeps running while we review it. If the date has passed and we have not confirmed a document, the discount stops from your next payment, and starts again once we confirm one.

We do our best to decide within a week of receiving your document. If we have not decided within 14 days, we get a daily reminder until we do.

The review ends in one of four ways:

• Confirmed – the document shows that you finished your degree; your discount becomes permanent, and we do not ask again.
• Declined – we do not find the document convincing. You can upload another one.
• Withdrawn – you press "Withdraw this document" before we decide. You can upload another one.
• No decision within 60 days – if we have not decided within 60 days of the first document you uploaded, it is deleted automatically. Uploading a different document in place of the one waiting for review does not add time. This is not a Decline: you can upload a document again, and a new 60 days begin. If you uploaded that first document by the date in our request, that date moves to 30 days after the deletion, so your discount keeps running while you upload again, and we email you.

Once one of the above has happened, the file is deleted, normally immediately; if a technical fault prevents this, the deletion is retried automatically, and we are alerted if it still fails.

After a Decline, a Withdraw or the automatic deletion after 60 days without a decision, your discount depends on the date in our request, as described above. Withdrawing a document never cancels your Expert discount itself, which rests on our contract with you (Art. 6(1)(b) GDPR).

Purpose: to set the price of your subscription – nothing else.

Legal bases: uploading a document and having it reviewed rest on your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time before we reach an outcome – we then stop the review and delete the file. Once we reach "approved" or "declined", the record of that outcome administers a price term of your subscription and rests on our contract with you (Art. 6(1)(b) GDPR). "We need more information" continues the same consent-based review and does not itself change your subscription.

You can see your own verification status in your account. No one else can.

We do not sell your personal data. We share it only with trusted service providers (sub-processors) who help us operate the Service on our behalf, under appropriate data-processing terms. These fall into the following categories:

• Cloud hosting and infrastructure
• Database, authentication, and file storage
• AI processing (to generate your personalised study content)
• Email delivery
• Payment processing for paid plans

A current list of the specific service providers we use is available on request at hello@brainamine.app.

Some of our providers are located outside the European Economic Area (e.g. the United States). Where data is transferred internationally, we rely on appropriate safeguards such as the EU Standard Contractual Clauses.

We keep your personal data for as long as your account is active. You can delete your content or your account at any time (see Account deletion for how); on deletion we remove your personal data, except where we must retain limited information to comply with legal obligations.

Under the GDPR you have the right to access, correct, delete, restrict, or object to the processing of your personal data, and the right to data portability and to withdraw consent. To exercise these rights, email hello@brainamine.app with "Privacy request" in the subject line. For deletion of your account or data, see Account deletion. You also have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde).

Brainamine is currently available only to users aged 14 or older. Users under 14 may not create or use an account during this launch phase.

Before you use the Service, we ask a neutral question about your age. We never store the number or date you enter. What happens next depends on where you are:

– If you are a new visitor and your answer is under 14, the Service stops on your device. No account or guest session is created, nothing is sent to our servers, and no result is stored.

– If your answer is 14 or older and you are trying the Service as a guest, a guest session is created and your device receives a time-limited confirmation (12 hours) that you answered 14 or older. We do not store the result for the guest session. If you later answer under 14 on that device, the confirmation is withdrawn and, again, nothing is stored.

– If your device still holds the guest confirmation that you answered 14 or older, and you then create an account, or log in to an account that has no recorded result yet, we record the result "14 or older" on that account, together with the time it was recorded. A result already recorded on that account stays as it is.

– If you log in directly to an account that has no recorded result, without such a guest confirmation, we ask the question in the account and record the result – "14 or older" or "under 14" – together with the time. If the result is "under 14", the account is blocked from further use; once recorded, this result cannot be changed to "14 or older" except through the correction process below.

If your account already has a recorded result, signing in does not ask the question again and does not change what is recorded.

Your exact date of birth is asked separately, later, and only before your first paid purchase.

If you believe your account's age result is wrong – for example because of a mistyped answer – you, or a parent or guardian, can email us at hello@brainamine.app with "Age correction" in the subject line. We review the request and, if it holds up, a member of our team applies the correction. The account stays blocked until a correction is applied. Please do not attach any identity document, certificate, or photo to this email – we do not ask for one. If one arrives unprompted, we do not copy its contents into our records, and it is deleted under our mailbox deletion schedule.

When we apply a correction, we keep a record of it: which of our team applied it, when, the result before and after, one of a small fixed set of reasons for the change, and – only if needed – a short internal note or reference to the support conversation, which our process is designed to keep free of identity or health information; the reference itself remains personal data, linkable to that conversation, until it is removed at the point described below. This record exists to show that a decision affecting a child-safety control was reviewed and made by a named, authorised person, and to keep the "14 or older" result accurate. The basis is our legitimate interest in keeping this control accurate and accountable (Art. 6(1)(f) GDPR). We keep the record for up to 7 years after the correction and then delete it. We do not keep any summary or statistics of corrections.

If you believe a child under 14 holds an account despite a "14 or older" result, email us at hello@brainamine.app with "Privacy request" in the subject line. We investigate the report and, if we confirm that the account holder is under 14, we delete or restrict the account (the steps on our Account deletion page also apply).

If you write to us with "Under 14" in the subject to ask when our under-14 programme will be available, we use your email address to send you that one update. We retain the whole message you send us – including your email address, the subject, timestamp, and anything else it contains – for no longer than 24 months. If the programme becomes available earlier, we send you that one update and permanently delete your message no later than 30 days after we send it, and in any event no later than 24 months after you sent it to us. We do not use its other contents for any purpose, and we ask that you not include any information about your child. The basis is our legitimate interest in responding to your request (Art. 6(1)(f) GDPR).

We use cookies and browser storage (local storage, session storage) only to run, secure, and remember your choices on the Service. We do not use any cookie or similar technology for advertising, analytics, or tracking, and none of the technologies below is shared with a third party.

Keeping you signed in and secure. A session cookie keeps you signed in; it lasts for your session and is cleared when you sign out. This session cookie is created the moment you use the Service as a guest – before you create an account or sign in – because the guest session and its confirmation are the starting point of the same sign-in mechanism this cookie maintains. A short-lived cookie (10 minutes) protects the sign-in process itself.

Remembering your choices. A cookie stores your chosen display language for up to 365 days. A separate entry in your browser records that you have seen our cookie notice, so we don't show it again, and is kept for up to 365 days.

Running the app you're using. Browser storage keeps track of things like whether you've completed onboarding, which plan features to show you, and the state of tools you're using (focus timer, reschedule, video, banners, explanation mode). These are kept only for as long as needed to run the feature they belong to. Two records – which in-app notices you've read or dismissed, and how many times your shared quizzes have been opened – work the same way, but with a 365-day limit: browser storage has no expiry of its own, so when you next use the Service, either record is discarded and, where needed, replaced with a fresh one if it was last saved more than 365 days before. If you never return, the record stays in your own browser, where we cannot reach it, until you clear your site data – see your browser's settings for how.

Setting up your account. While you're setting up your account, your browser holds the answers you give before the account exists (for example the introductory questions); it never holds the date of birth you enter, at any point (see "Minimum age" above). These answers are cleared as soon as your account is set up. If you try Brainamine as a guest, your device holds the signed 14-or-older confirmation described above. If you later create an account, or log in to one, a single-use secret lets us attach the quizzes and reviews you did as a guest to that account. Your browser's copy of this secret is deleted as soon as the hand-off finishes. We store only a cryptographic hash of it, which grants no access to any account and cannot be used to read your data. We keep that hash only as follows: if the hand-off finishes normally, for up to 7 days afterwards (to investigate the rare case where it turns out to have failed); if the hand-off is interrupted after your guest work has already been attached but before the last step completes, until that step completes, and in any case no more than 30 days after the attachment – deleting the hash sooner would otherwise wrongly tell you your guest work could not be attached, when it was; and if the secret is never used at all, for up to 30 days after it was created. In every case the hash is then deleted automatically. The guest device's own read/dismissed record of in-app notices is deleted once your account's record takes over. If we cannot attach your guest work when you sign in, we tell you once on your dashboard and then remove that notice. Legal basis: taking these steps at your request when you choose to try Brainamine before or during creating an account (Art. 6(1)(b) GDPR), and our legitimate interest in providing this feature securely (Art. 6(1)(f) GDPR).

We currently do not use any cookie or similar technology that requires your consent under § 165 Abs. 3 TKG 2021. If that changes, we will ask for your consent first, through a dedicated banner, before any such technology is activated.

We use technical and organisational measures to protect your data, including encryption in transit and access controls. No method of transmission or storage is completely secure, but we work to protect your information.

We may update this Policy from time to time. We will update the "Last updated" date above and, where appropriate, notify you of material changes.

Brainamine – hello@brainamine.app