Sublimind – Privacy Policy

Last updated: 14.12.2025

This Privacy Policy explains how Bright Code Holdings SRL (“Sublimind”, “we”, “us”, or “our”) collects, uses, shares, and protects information when you use the Sublimind mobile applications, our website at https://sublimind.app, and related services (collectively, the “Service”).

By using the Service, you agree to the practices described in this Privacy Policy.

If you do not agree, do not use the Service.

1) Summary (Plain English)

We collect information needed to run Sublimind (account details, app usage, subscription status).
If you use Custom Subliminals, we process the text you type (“User Input”) to generate your custom audio track.
Purchases are handled by the Apple App Store / Google Play. We receive subscription and entitlement status (not your full card details).
We use service providers to host the Service, generate audio, run analytics, and provide customer support.
You can request deletion of your account and data, and you can delete custom tracks inside the app.

2) Who We Are

Controller (for GDPR purposes): Bright Code Holdings SRL
Website: https://sublimind.app
Contact: privacy@sublimind.app (or support@sublimind.app)

If you are in the EEA/UK, “controller” means the entity responsible for deciding how and why personal data is processed.

3) Information We Collect

We collect information in these categories:

A) Account and Identity Information

Email address
Sign-in identifiers from Apple/Google (as provided by those providers)
Account ID and authentication tokens
Basic profile settings (e.g., preferences inside the app)

B) User Input for Custom Subliminals

If you use the Custom Subliminal feature, we process:

The goal description and any text you submit (User Input)
Your selected options related to custom creation (if applicable)

Important: Please do not enter highly sensitive personal information (for example: medical diagnoses, detailed trauma history, or other sensitive identifiers) into User Input. If you do, we may still process it to provide the feature you requested.

C) Generated Content and Custom Data

When you generate a Custom Subliminal, we may store:

Custom track metadata (title, image selection, timestamps)
Generation status and diagnostics (e.g., queued, generating, ready, failed)
Preview metadata (e.g., interpreted goal, themes, benefits)
Your generated audio track(s)

D) App Usage and Interaction Data

Screens viewed, taps/clicks, feature usage
Listening activity (e.g., play/pause events, session timestamps)
Library browsing, article views and completion (Learning Center)
Reminders configuration (time, frequency settings)

E) Device, Technical, and Diagnostic Data

Device type/model, OS version, app version
Language/locale, time zone (approx.)
IP address (generally collected by servers when you connect)
Crash logs, performance data, error diagnostics
Push notification token (if you enable notifications)

F) Subscription and Purchase Information

Subscription status (active/inactive), product identifiers, entitlement state
Purchase receipts or transaction identifiers as needed to validate access
We do not receive your full payment card number from Apple/Google.

G) Website Data (if you use sublimind.app)

Depending on your browsing and settings, our website may collect:

Standard web logs (IP address, user agent)
Cookies or similar technologies for basic functionality and analytics (where used)

4) Special Categories / Sensitive Data

We do not intend to collect “special categories” of data (such as health data) as a core part of the Service.

However, because User Input is free text, you may choose to provide sensitive information. If you do, we will process it only as needed to provide the Service (for example, to generate a Custom Subliminal you requested), and in accordance with this Privacy Policy.

5) How We Use Your Information

We use information for the following purposes:

A) Provide and Operate the Service

Create and manage your account
Provide access to the library and Learning Center
Enable playback and reminders
Sync your data across devices (where applicable)

B) Generate Custom Subliminals

Process your User Input to produce preview information (goal, themes, benefits)
Generate affirmations and audio output
Store and deliver your custom tracks and metadata

C) Subscriptions, Credits, and Entitlements

Validate subscription status and Lifetime Credits
Enforce access rules (e.g., subscription-only customs playable while subscribed)
Restore purchases and prevent fraud/abuse

D) Improve and Secure the Service

Debugging, crash reporting, performance monitoring
Security monitoring and abuse prevention
Product analytics to understand feature usage and improve UX

E) Support and Communications

Respond to support requests
Send service-related messages (e.g., account, billing, security, or important updates)
Send optional reminders/notifications (only if enabled)

F) Legal and Compliance

Comply with legal obligations and enforce our Terms
Protect rights, safety, and integrity of the Service

6) Legal Bases for Processing (EEA/UK)

If GDPR/UK GDPR applies, we rely on these legal bases:

Contract (Art. 6(1)(b)): to provide the Service you request (account, playback, custom generation, entitlements).
Legitimate Interests (Art. 6(1)(f)): to secure, improve, and operate the Service (fraud prevention, analytics, debugging), where not overridden by your rights.
Consent (Art. 6(1)(a)): for optional features such as push notifications (and cookies where applicable).
Legal Obligation (Art. 6(1)(c)): where we must comply with law (tax, compliance, lawful requests).

You can withdraw consent at any time (for example, by disabling notifications).

We do not sell your personal information.

We may share information with:

A) Service Providers (Processors)

Vendors that help us operate the Service, such as:

Cloud hosting, storage, and content delivery
Analytics and performance monitoring
Crash reporting and error tracking
Customer support tooling
Push notification delivery services
AI/automation providers that help process User Input and generate preview content
Text-to-speech (TTS) and audio processing providers used to generate audio tracks

These providers are authorized to process data only as needed to provide services to us.

B) App Stores and Payment Platforms

Apple App Store and Google Play handle payments and may provide us with purchase/receipt and subscription status information needed to validate access.

C) Legal, Safety, and Compliance

We may disclose information if we believe it is reasonably necessary to:

comply with law, regulation, legal process, or governmental request;
enforce our Terms, investigate fraud, or protect the Service; or
protect the rights, property, or safety of users, Sublimind, or others.

D) Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to standard confidentiality safeguards.

8) International Transfers

We may process and store information in countries other than where you live, including outside the EEA/UK.

When we transfer personal data internationally, we rely on appropriate safeguards such as:

Standard Contractual Clauses (SCCs) where applicable, and/or
adequacy decisions or other lawful mechanisms recognized by relevant authorities.

9) Data Retention

We keep personal data only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Typical retention (high level):

Account data: retained while your account is active; deleted or anonymized after deletion requests, subject to legal requirements.
Custom Subliminal metadata and audio: retained until you delete it in-app or delete your account (subject to backups and legal retention).
Diagnostics/security logs: retained for a limited period to troubleshoot and secure the Service.
Subscription records: retained as required for accounting, compliance, and dispute handling.

Backups may persist for a limited period even after deletion.

10) Your Choices and Controls

A) Access and Update

You can update some account settings within the app.

B) Delete Custom Content

You can delete custom tracks inside the app (where the UI provides deletion controls). Deletion may take time to propagate to backups.

C) Account Deletion

You may request account deletion via in-app options (if available) or by contacting us at privacy@sublimind.app or support@sublimind.app.

D) Notifications

You can enable/disable notifications in your device settings at any time.

E) Analytics Controls

Where required by law, we will offer consent mechanisms (e.g., cookie banners on the website). In the app, some analytics may be necessary for essential operation, fraud prevention, and service improvement.

11) Your Rights (EEA/UK and Similar Regions)

Depending on your location, you may have rights to:

Access your personal data
Correct inaccurate data
Delete your data
Restrict or object to processing
Data portability
Withdraw consent (where processing is based on consent)

To exercise rights, email privacy@sublimind.app. We may need to verify your identity.

You also have the right to lodge a complaint with your local data protection authority.

12) California Privacy Rights (CPRA/CCPA)

If you are a California resident, you may have rights including:

The right to know what personal information we collect, use, and disclose
The right to request deletion
The right to correct inaccurate information
The right to opt out of certain sharing (we do not sell personal information)

To submit a request, contact privacy@sublimind.app.