Privacy Policy

Last updated: May 3, 2026

BrainBeat ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and safeguard your information when you use our mobile application and related services.

1. Information We Collect

1.1 Account Information

Email address and display name when you create an account, or Apple ID / Google ID if you use social sign-in.

1.2 Learning Data

Vocabulary progress, session history, language preferences, CEFR level, flashcards, dialogue transcripts, and learning statistics.

1.3 Health & Safety Consent Data

Before using binaural audio features, we collect your explicit acknowledgement regarding pre-existing conditions (epilepsy history, cardiac pacemaker, pregnancy). This data is classified as special category data under GDPR Article 9 and sensitive personal data under LGPD Article 11. We collect this solely to ensure your safety and comply with Apple App Review Guidelines (Guideline 1.4). The legal basis for this processing is your explicit consent (GDPR Art. 9(2)(a)).

1.4 Device & Technical Information

Device type, operating system version, app version, IP address (captured automatically for security monitoring), and user agent string.

1.5 Voice Input

When you use pronunciation practice or voice recording features, audio is processed in real-time by our text-to-speech provider. We do not store voice recordings on our servers. Voice processing is handled by ElevenLabs (see Section 5).

1.6 Usage Analytics

Anonymous session events (session start/end, feature usage) for improving the app. No personally identifiable information is included in analytics events.

1.7 Crash Reports

In the event of app crashes, diagnostic data (including a pseudonymised user identifier) is sent to our crash reporting service (see Section 5).

2. Information We Do NOT Collect

3. Legal Basis for Processing (GDPR Art. 6 & Art. 9)

Data CategoryLegal BasisPurpose
Account informationContract performance (Art. 6(1)(b))Provide the service
Learning dataContract performance (Art. 6(1)(b))Track progress, personalise experience
Health & safety consentExplicit consent (Art. 9(2)(a))User safety, regulatory compliance
Device/technical infoLegitimate interest (Art. 6(1)(f))Security, compatibility, support
Usage analyticsLegitimate interest (Art. 6(1)(f))Improve the app
Crash reportsLegitimate interest (Art. 6(1)(f))Fix bugs, maintain stability

4. How We Use Your Information

5. Third-Party Services (Sub-Processors)

We use the following third-party services to operate BrainBeat:

ServicePurposeData ProcessedLocation
SupabaseDatabase, authentication, edge functionsAll account and learning dataEU (Frankfurt)
Anthropic (Claude)AI dialogue and conversation generationConversation context (no PII sent)USA
ElevenLabsText-to-speech voice synthesisText for voice generation (no PII)USA
RevenueCatSubscription and payment managementPurchase receipts, subscription statusUSA
SentryCrash reporting and error trackingPseudonymised user ID, crash diagnosticsUSA
CloudflareCDN, DDoS protection, WAFIP address, request metadataGlobal (EU included)
Expo/EASApp builds and over-the-air updatesBuild metadata (no user data)USA
Apple / GoogleApp distribution, in-app purchasesAs per their respective privacy policiesUSA / Global

For transfers to the USA, we rely on Standard Contractual Clauses (SCCs) as approved by the European Commission, or the service provider's participation in adequate safeguard mechanisms (GDPR Art. 46).

6. Data Storage, Security & Retention

Your primary data is stored on Supabase servers in the European Union (Frankfurt, Germany). We use industry-standard encryption for data in transit (TLS 1.3) and at rest (AES-256). Access is restricted via Row Level Security policies and service-role authentication.

Retention Periods

DataRetention
Account & learning dataUntil account deletion or 1 year after last activity
Health consent recordsUntil account deletion (required for legal compliance)
Analytics events90 days
Crash reports90 days (Sentry default)
Rate limiting logs24 hours
API usage logs30 days

7. Your Rights

7.1 GDPR Rights (EEA Residents)

Under the General Data Protection Regulation, you have the right to:

You may also lodge a complaint with your national Data Protection Authority. For Portugal: CNPD.

7.2 CCPA Rights (California Residents)

Under the California Consumer Privacy Act, California residents have the right to:

To exercise your CCPA rights, email privacy@brainbeat.app.

7.3 LGPD Rights (Brazilian Residents)

Under the Lei Geral de Protecao de Dados (LGPD), Brazilian residents have the right to:

To exercise your LGPD rights, email privacy@brainbeat.app.

7.4 How to Exercise Your Rights

For all privacy requests, contact us at privacy@brainbeat.app. We will respond within 30 days. You may also delete your account directly within the app (Settings > Delete Account), which permanently removes all your data from our servers.

8. Children's Privacy

BrainBeat is rated 12+ and recommended for users aged 14 and above. Users under 14 should use BrainBeat only with parental supervision. We do not knowingly collect personal information from children under 13 (COPPA) or under 16 without parental consent (GDPR Art. 8). If you believe a child has provided us with personal information without parental consent, please contact us immediately.

9. International Data Transfers

Your primary data is stored in the EU. Some sub-processors (Anthropic, ElevenLabs, RevenueCat, Sentry) are based in the United States. For these transfers, we rely on:

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. For significant changes affecting your rights, we will notify you via email or in-app notification.

11. Contact Us

For privacy-related inquiries, data requests, or concerns: