Privacy Policy
Effective date: August 14, 2026
1. Who we are. NETMIND CLOUD LLC, 1621 Central Ave, Cheyenne, Wyoming 82001, USA (“we”), operates this language-learning 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 or Google we receive your email address or, where the provider hides it, a provider identifier. On Android, signing in with Google also provides 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. We never receive or store your password. (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 your plan, and your preferences (app language, course, appearance). (d) Purchase data: where you buy a subscription through an app store, we receive your subscription status from that store. We do not collect your device model or your app version; we do not record audio; and we do not collect sensitive categories of data, precise location, or contacts.
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; and to improve the Service using aggregated, non-identifying statistics.
4. Legal bases. Performance of the contract (providing the Service), your consent where required, and our legitimate interest in securing and improving the Service.
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. Using the Service from other countries implies international transfer of your data to those servers.
6. Sharing. We do not sell personal data and do not show third-party advertising. We share data only with the processors above, with app stores for payment management, and where required by law.
7. Retention. We keep your data while your account is active. If you delete your account, personal data is removed or anonymized within a reasonable period, except where retention is legally required.
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 16 and over. We do not knowingly create accounts for anyone under 16, and we do not ask for or store a date of birth. If you believe a person under 16 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. If you join our waitlist, we collect your email address, with your consent, to send you updates about Tulbrain’s launch and founding-member campaign. 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 message includes an unsubscribe link, and unsubscribing deletes your address. You can also request deletion at any time by writing to hello@netmindcloud.com.
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. Our hosting provider (see section 5) 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.