Privacy Policy

Version 1.0

Last Updated: January 31, 2026

Effective Date: January 31, 2026

Introduction

This Privacy Policy explains how Cenk Basbolat (“we,” “us,” or “our”) collects, uses, stores, and protects your personal information when you use Mindbend (the “App”) or visit our website.

We are committed to protecting your privacy and being transparent about our data practices. This policy applies to:

  • Our website (mindbend.app)
  • The Mindbend mobile app (iOS and Android)
  • Marketing communications and waitlist

Contact Information:

Cenk Basbolat

Email: support@mindbend.app

Address: Via Giulio Salvetti, 20, Rovereto, Trento 38068, Italy

1. Information We Collect

1.1 Information You Provide

Account Information:

  • Name
  • Email address
  • Age
  • Gender
  • Password (encrypted)

Wellness & Practice Data:

  • Emotional check-ins and mood tracking
  • Goals and intentions you set
  • Journal entries and gratitude logs
  • Meditation session data (duration, type, completion)
  • Practice feedback and ratings
  • Voice recordings (when using voice features)
  • AI assistant conversations (practice requests, custom instructions, questions, feedback)

Marketing Communications:

  • Email address and name from waitlist signups
  • Communication preferences
  • Response to marketing emails

Payment Information:

  • Processed by Apple (App Store) and Google (Google Play)
  • We do not store credit card or payment details
  • We receive transaction confirmations and subscription status

Support Communications:

  • Messages you send to customer support
  • Bug reports and feedback

1.2 Information Collected Automatically

Usage Data:

  • App features you use and how often
  • Session duration and frequency
  • Practice patterns and preferences
  • Navigation paths within the app

Device Information:

  • Device type and model
  • Operating system version
  • App version
  • Device identifiers (not personally identifiable)
  • IP address
  • Browser type (website only)

Analytics Data:

  • Crash reports and error logs
  • Performance metrics
  • Aggregated usage statistics

1.3 Information We Do NOT Collect

  • Precise geolocation data
  • Contacts or address book
  • Photos or camera access (except for profile pictures, if implemented)
  • Microphone access outside of voice features
  • Social media account information

2. How We Use Your Information

2.1 Core Service Delivery

Personalized Experience:

  • Train a private AI model specific to you
  • Generate meditation practices tailored to your emotional state
  • Adapt content based on your goals and feedback
  • Recommend practices that work best for you

Account Management:

  • Create and maintain your account
  • Authenticate your identity
  • Process subscription payments (via Apple/Google)
  • Provide customer support

2.2 Product Improvement

  • Analyze usage patterns to improve features
  • Fix bugs and technical issues
  • Test new features and improvements
  • Understand what content works best

2.3 Marketing Communications

  • Send waitlist updates and launch announcements
  • Share product updates and new features
  • Send promotional offers (with your consent)
  • Conduct user research and surveys

You can opt out of marketing emails at any time by:

  • Clicking “unsubscribe” in any marketing email
  • Updating preferences in the app settings
  • Emailing support@mindbend.app

2.4 Research & Development

Anonymized Data:

We may aggregate and anonymize your data (removing all personal identifiers) for:

  • Training general AI models
  • Publishing research insights
  • Industry reporting
  • Potential licensing to third parties for AI training

Once anonymized, this data cannot be linked back to you and is no longer considered personal information under GDPR.

2.5 Legal & Safety

  • Comply with legal obligations
  • Enforce our Terms & Conditions
  • Protect against fraud or security threats
  • Respond to legal requests from authorities

3. Legal Basis for Processing (GDPR)

If you are in the EU/EEA, we process your data based on:

Consent:

  • Marketing communications
  • Optional data collection (e.g., detailed emotional data)

Contract Performance:

  • Providing the app service
  • Account management
  • Processing payments

Legitimate Interests:

  • Product improvement and analytics
  • Security and fraud prevention
  • Anonymized research

Legal Obligation:

  • Complying with tax and legal requirements
  • Responding to legal requests

4. How We Share Your Information

4.1 We Do NOT Sell Personal Data

We do not sell your name, email, wellness data, or any personally identifiable information to third parties.

We may sell or license anonymized, aggregated data that cannot identify you to third parties for AI training and research purposes.

4.2 Third-Party Service Providers

We share data with trusted service providers who help us operate the app:

Infrastructure & Hosting:

  • Google Cloud Platform: Hosting, databases, infrastructure
  • Data stored in EU and US data centers

AI & Machine Learning:

  • Google Cloud (Gemini): AI content generation
  • Botpress: Conversational AI and chat processing
  • Data is processed to generate personalized content

Voice Processing:

  • ElevenLabs: Text-to-speech (meditation narration)
  • Deepgram: Speech-to-text (voice input)
  • Microsoft Azure: Backup text-to-speech
  • Voice data processed in real-time, not stored long-term

Payment Processing:

  • Apple (App Store): iOS subscriptions
  • Google (Google Play): Android subscriptions
  • Subject to Apple and Google privacy policies

Analytics (if applicable):

  • Crash reporting and performance monitoring
  • Aggregated, non-personal analytics

All service providers:

  • Are bound by strict data processing agreements
  • Process data only as instructed by us
  • Are required to protect your data
  • Are GDPR-compliant (for EU users)

4.3 Legal Disclosure

We may disclose your information if required by law or to:

  • Respond to legal process (court orders, subpoenas)
  • Protect our rights or property
  • Prevent fraud or security threats
  • Protect user safety in emergencies

4.4 Business Transfers

If Mindbend is acquired or merged, your data may be transferred to the new entity. You will be notified of any such change.

5. Data Storage & Security

5.1 Where We Store Data

  • Primary: Google Cloud data centers (EU and US regions)
  • Backups: Encrypted cloud storage

International Transfers:

If you are in the EU, your data may be transferred to the US for processing. We use standard contractual clauses and ensure GDPR-compliant safeguards.

5.2 Security Measures

Technical Safeguards:

  • Encryption in transit (TLS/SSL)
  • Encryption at rest for sensitive data
  • Secure authentication (password hashing)
  • Regular security audits
  • Access controls and logging

Organizational Safeguards:

  • Limited employee access to personal data
  • Data processing agreements with vendors
  • Incident response procedures

No system is 100% secure. While we implement industry-standard security measures, we cannot guarantee absolute security. You are responsible for keeping your password secure.

5.3 Data Retention

Active Accounts:

  • Account data: Retained while your account is active
  • Wellness data: Retained to power your personalized model
  • Usage data: Retained for up to 2 years for analytics

Deleted Accounts:

  • Personal information deleted within 14 days
  • Anonymized data may be retained indefinitely
  • Backup systems purged within 30 days

Inactive Accounts:

  • After 2 years of inactivity, we may delete your account with notice

Marketing Data:

  • Waitlist emails retained until you opt out or launch completes
  • Marketing opt-outs processed immediately

6. Your Privacy Rights

6.1 Rights for EU/EEA Users (GDPR)

You have the right to:

Access: Request a copy of your personal data

Rectification: Correct inaccurate data

Erasure (“Right to be Forgotten”): Request deletion of your data

Restriction: Limit how we process your data

Portability: Receive your data in a portable format

Object: Opt out of certain data processing

Withdraw Consent: For consent-based processing

Lodge a Complaint: With your local data protection authority

How to exercise your rights:

Email: support@mindbend.app

We will respond within 30 days (as required by GDPR)

6.2 Rights for California Users (CCPA)

You have the right to:

Know: What personal information we collect and how it’s used

Delete: Request deletion of your personal information

Opt-Out: Opt out of sale of personal information

Non-Discrimination: Equal service regardless of privacy choices

We do not sell personal information. However, we may sell anonymized, aggregated data.

How to exercise your rights:

Email: support@mindbend.app

We will respond within 45 days (as required by CCPA)

6.3 Rights for All Users

Account Deletion:

Data Export:

  • Request a copy of your data by emailing support@mindbend.app
  • Delivered in JSON or CSV format within 30 days

Marketing Opt-Out:

  • Click “unsubscribe” in any marketing email
  • Update preferences in app settings

7. Children’s Privacy

Minimum Age: 13 years old

Mindbend is not intended for children under 13. We do not knowingly collect data from children under 13.

Ages 13-17:

Users between 13-17 should have parental or guardian consent to use the app.

If we learn we have collected data from a child under 13, we will delete it immediately. If you believe we have data from a child under 13, contact us at support@mindbend.app.

8. Cookies & Tracking (Website)

8.1 What We Use

Essential Cookies:

  • Session management
  • Security and fraud prevention
  • Required for website functionality

Analytics Cookies (if applicable):

  • Website usage and performance
  • Aggregated visitor statistics
  • Can be disabled in browser settings

Marketing Cookies (if applicable):

  • Track effectiveness of campaigns
  • Personalize marketing content
  • Require consent before placement

8.2 Your Choices

  • Disable cookies in your browser settings
  • Use browser privacy extensions
  • Opt out of analytics tracking

Note: Disabling essential cookies may affect website functionality.

9. Third-Party Links

The app or website may contain links to third-party sites (e.g., support articles, social media).

We are not responsible for:

  • Third-party privacy practices
  • Content on external sites
  • Data collection by other services

Please review the privacy policies of any third-party sites you visit.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do:

  • Update the “Last Updated” date at the top
  • Notify you via email for material changes
  • Post notification in the app
  • Continued use constitutes acceptance

We encourage you to review this policy periodically.

11. Contact Us

For privacy questions, data requests, or concerns:

Email: support@mindbend.app

Data Protection Officer (if applicable):

Currently, Mindbend does not have a dedicated DPO. All privacy inquiries should be directed to the email above.

Mail:

Cenk Basbolat

Via Giulio Salvetti, 20

Rovereto, Trento 38068

Italy

EU Users:

If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority.

Version History

v1.0 (January 31, 2026): Initial Privacy Policy

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