Privacy Policy

We take the protection of your personal data seriously and process it confidentially in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and the German Telecommunications Digital Services Data Protection Act (TDDDG). This policy explains what personal data we process and why. It covers both the website brainmute.app and the Brainmute Android app. Sections 3 to 5 and 11 to 12 are about the website, sections 6 to 10 are about the app, and the rest applies to both.

1. Controller

Controller within the meaning of Art. 4 (7) GDPR is:

A data protection officer is not required by law (no core activity of regular, large-scale or sensitive data processing under Art. 37 GDPR / § 38 BDSG).

For residents of Quebec (Canada), the Act respecting the protection of personal information in the private sector requires a designated person in charge of the protection of personal information. This function is exercised by the person with the highest authority in the enterprise: Luis Kleemann, owner of the sole proprietorship. Contact: support@brainmute.app, or by post at the address above.

Wherever the law of another country requires us to name a contact for data protection matters, this is also Luis Kleemann, at support@brainmute.app or by post at the address above. This applies in particular to Singapore (Personal Data Protection Act 2012, person responsible for data protection) and Chile (Law 21.719, contact for data subjects and for the data protection agency).

2. Legal bases

Where we process personal data, we rely on the following legal bases:

• Art. 6 (1) (b) GDPR (pre-contractual or contractual measures), for example when we handle an email enquiry.
• Art. 6 (1) (f) GDPR (legitimate interest), for example for the operation, security and stability of the site, and spam and abuse prevention.
• § 25 (2) no. 2 TDDDG (storage of or access to information on your device where strictly necessary for a service you explicitly requested), for example for the app lock.

3. Hosting and server log files

Our website is hosted by:

Further information can be found in Cloudflare's privacy policy.

When you visit the site, Cloudflare automatically processes the following data in server log files, which your browser transmits for technical reasons: IP address, date and time of access, requested file, amount of data transferred, HTTP status code, browser type and version, operating system, and referrer URL.

Purpose: delivery of the website, IT security, and defence against attacks and bot traffic.
Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in a technically sound and secure website).
Storage period: server log files are kept for a maximum of 14 days. This data is not merged with other data sources.

4. Content delivery network and security

Cloudflare is also used as a content delivery network (CDN) and web application firewall (WAF). All traffic between your browser and our site is routed through Cloudflare's global network and malicious requests are filtered out. Processing your IP address is technically necessary for this.

Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in the performance and security of the site).

5. Self-hosted fonts

This site uses the fonts Inter, JetBrains Mono, Space Grotesk and Instrument Serif (all under the SIL Open Font License). The font files are served exclusively from our own server (Cloudflare Pages). No connection to Google Fonts or any external font CDN is made when the fonts are loaded, so no IP address is transmitted to a font provider.

Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in a consistent presentation).

6. The app: what never leaves your phone

Brainmute is an Android app that locks distracting apps and gives you missions. Most of what it needs to do that stays on your device and is never sent to us.

• Which app is open right now. To lock an app, Brainmute has to know which app you just opened. It reads that from Android and holds it in memory only, for as long as it takes to decide whether to show the lock screen. It is never sent anywhere. One exception stays on your phone: if you use the emergency unlock during your sleep window, the app remembers which app you unlocked until that unlock ends.
• Your screen time. The app lock uses Android's usage access only to see which app is currently open, so that a lock comes back on when your unlocked time runs out. Earlier versions also offered an optional screen time report. This feature is no longer available in the current version. The copy of the plan that was previously also stored on our server has been deleted from our active database. Any remaining backup copies may temporarily contain such data. These backup copies are not used for ongoing operations (see section 7).
• Your step count. If you allow it, the app reads your step count for movement missions. This stays on the device.
• Which apps you chose to lock. The list of apps you lock, and the list of apps you still allow during a mission, stays on your device. We deliberately do not sync it, because the name of a locked app could reveal something sensitive about you, for example a health, prayer or dating app. If you switch phones you pick your apps again.
• The list of your apps. So that you can choose which apps to lock, the app reads the list of apps on your phone that you can open, with their names and icons. This list stays on your device.
• Your exact age. The app asks for it and keeps it on the device. Only the plain confirmation that you are at least 16 is stored on our server, never the number itself.
• What you write during a mission. Some missions ask you to write. The app counts your words while you type, and the text is discarded when the mission ends. It is not saved and not sent to us.

Legal basis: Art. 6 (1) (b) GDPR, because this is how the service you asked for works, and § 25 (2) no. 2 TDDDG for the access to your device that this needs. Nothing here is processed for any other purpose.

7. The app: what we store on our server

Your account keeps a copy of part of your data on our server, so you do not lose your progress when you change or reset your phone. This is the complete list.

• Your profile: your account ID and your display name. Your display name is only shown to you. Other users cannot see it or search for it.
• Your progress: your streak in days, your experience points, your time balance (the minutes you earned with missions and have not used yet), and how many missions you completed and how much time they took in total.
• Your settings: your sleep schedule, your goals and focus area, the confirmation that you are at least 16, your streak freezes and the days on which your streak was frozen or revived, how many nights in a row you kept your sleep window, which of today's missions you completed, and when your trial started.
• Your mission calendar: for each day, which missions you completed, gave up or failed, with the kind of mission, its goal (for example 4,000 steps or 20 minutes), its area, its icon, the minutes you earned and, if it failed, the reason (for example that you gave up). The value that was actually measured (how many steps, minutes or words you reached) is removed before this is sent, and so are the names of missions you created yourself.
• Your subscription: whether you are in a trial or have an active, paused or expired subscription, which plan, when the trial started, when the current period ends and whether it renews. We also keep a short record of each subscription event that RevenueCat reports to us (for example a purchase, a renewal or a cancellation, with the plan and its dates), so that no event is processed twice and your subscription status can be traced. These records contain no payment details, no price and no country.
• Your subscription emails: the price and currency of your last payment, and a record of which subscription email we sent you (confirmation, trial reminder or renewal reminder), for which period, and when. See section 9.

Previous screen time plans. Earlier versions of the app could create a plan from your voluntarily generated screen time report, containing your five most-used apps as suggested apps to block, a target value and a short assessment of your usage. Until 3 October 2026, this plan was also stored on our server together with your other settings. Since that date, no new screen time plans have been uploaded to our server. The server copies stored previously have been deleted from our active database. Any remaining backup copies may temporarily contain such data. These backup copies are not used for ongoing operations.

Purpose: to keep your progress across devices and to know whether your subscription is active.
Legal basis: Art. 6 (1) (b) GDPR.
Processor: Supabase, for the database and for sign-in. The database is hosted in Frankfurt, Germany (region eu-central-1). We have a data processing agreement in place.

The app does not use advertising, marketing or user tracking. There is no Google Analytics, no Meta pixel, no TikTok pixel and no advertising ID. The subscription statistics we receive from RevenueCat and the technical information the Google Play Billing Library sends to Google are described in section 9. We do not send push notifications from a server, so no push token is created or transmitted.

8. Your account and sign-in

Brainmute requires an account. You create it at the start, and the app cannot be used without one. To create it you need an email address or a Google account. There is no anonymous use.

You can sign up with an email address and a password, or with your Google account. If you use Google, we receive your email address and your Google account ID from Google in order to identify you. We do not receive your password. We do not store your name or your profile picture: both are removed automatically when your account is created and whenever it changes, before anything is written to our database. Google processes your data for the sign-in itself as an independent controller, under its own privacy policy.

We send emails to your address for your account: the verification code when you sign up, password resets, confirmation when you change your address, confirmation after you delete your account, and the subscription emails described in section 9. So that these emails reach you in the language you use the app in, we store with your account whether the app is set to English or German. There are also two security notices that you cannot unsubscribe from, because they protect your account: one when your password has been changed, and one when your email address has been changed. Sending is handled for us by Scaleway SAS, 8 rue de la Ville-l’Évêque, 75008 Paris, France. The data processed are the sender address, the recipient address, the subject, the content of the email, the timestamp and the response of the receiving mail server. Processing takes place in France. According to Scaleway, no personal data is processed outside the European Union for this service and no sub-processors outside the European Union are used for it.

If an address cannot be reached, Scaleway puts it on a blocklist so that no further delivery attempts are made. The address, the reason and the period of the block are stored. The first block lasts one week, the second one month, and from the third onwards it has no time limit. We can unblock an address again.

If you create an account but do not confirm it with the code from our email, we delete it again no later than 48 hours after it was created, together with the address you gave. If you do not use your account again after its first 24 hours, we delete it 90 days after it was created, together with everything listed in section 7 and your record at RevenueCat, unless you have bought a subscription or started a free trial with it. Signing in, or opening the app while you are signed in, counts as use.

So that nobody can abuse our sign-up and our email sending, we limit how often an email can be requested for an address in a row. For this we do not store your address, only a check value calculated from it, from which the address cannot be recovered. These entries are deleted after two days at the latest.

We do not pass on your IP address. The app does not send it to us, and we do not forward it to any provider. Supabase sees the IP address your device connects from and stores it in two places: in its technical logs, which are kept for one day, and with your sign-in, together with the technical identifier of the program making the connection (user agent). Only the most recent connection is kept with your sign-in. It is overwritten with each new one and deleted as soon as you sign out or delete your account.

Purpose: to identify you, to restore your data on a new device, to deliver the emails for your account, and to protect our sign-up from abuse.
Legal basis: Art. 6 (1) (b) GDPR. For the blocklist, the limit on requests and the deletion of unconfirmed and unused accounts Art. 6 (1) (f) GDPR; our legitimate interest is reliable delivery, protection against being blocked by mail providers, protection against abuse, and not keeping data we no longer need. For the security notices about your password and your address Art. 6 (1) (f) GDPR; our legitimate interest is the security of your account.

9. Subscription and payment

Brainmute is sold as a subscription through the Google Play Store. We never see your payment details. Your card, your address and your bank data are handled by Google and never reach us. Google Play processes your purchase and your payment as an independent controller, under its own terms and privacy policy. In the European Economic Area and the United Kingdom, Google is also the seller of the subscription (see our Terms, section 7).

To handle subscriptions, the app contains Google's Play Billing Library. The library also sends Google technical information about how it is used, such as successful and failed operations and problems connecting to Google Play. This can happen when the app starts, even if you do not buy anything. Google uses this information for its own purposes, in particular to improve the library and to help with technical errors, and is itself responsible for this under its own privacy policy, which names the Google company responsible for your country.

To know whether your subscription is active, we use RevenueCat, Inc., 1 Letterman Drive, San Francisco, CA 94129, USA. The app gives RevenueCat your account ID, and RevenueCat receives your purchase history from Google Play: which plan you bought, when, and Google's confirmation of the purchase. Like any server, RevenueCat also receives the technical details of each connection, such as your IP address. With each request, the app also sends RevenueCat the app version, the Android version, the manufacturer and model of your phone, your language settings and the country of your Google Play account. RevenueCat works out your approximate country from your IP address and then discards the IP address. We do not give RevenueCat your name, your email address or an advertising ID, and we do not use any of its advertising or analytics integrations. RevenueCat tells us whether you have an active subscription and shows us statistics about our subscriptions based on this purchase information, such as active subscriptions, revenue and new customers. RevenueCat acts as our processor in doing so, see section 13.

If you delete your account, we also delete your record at RevenueCat, that is the subscription status and purchase history stored there under your account ID, and the subscription information on our own server (section 7). Your purchase itself is held by Google: an active subscription continues and continues to be charged until you cancel it in the Google Play Store.

Purpose: to unlock the app for paying users, and to understand how our subscriptions are doing.
Legal basis: Art. 6 (1) (b) GDPR for unlocking the app. Art. 6 (1) (f) GDPR for the subscription statistics; our legitimate interest is to understand and manage our subscription business. Art. 6 (1) (f) GDPR for building in the Google Play Billing Library and the technical information it sends; our legitimate interest is a reliable payment system.
Third country: RevenueCat and Google LLC are in the USA, see section 13.

Subscription emails. We send you three kinds of email about your subscription: a confirmation with the terms of your subscription and how to cancel it, after you subscribe; a reminder about two days before a free trial turns into a paid subscription; and, for yearly plans, a reminder 15 to 30 days before your subscription renews. These emails are not advertising, and you cannot unsubscribe from them, because they are part of your subscription and several laws require them (for example in California, Business and Professions Code § 17602). For the renewal reminder we need the price, so we keep the price and currency of your last payment as RevenueCat reports it to us. We also keep a record of which of these emails we sent you, for which period and when, so that you never receive the same reminder twice and so that we can prove that it was sent. The emails are sent through Scaleway (section 8).
Legal basis: Art. 6 (1) (b) GDPR and Art. 6 (1) (c) GDPR, where a law requires the email.
Storage period: the price until your account is deleted; the record of sent emails for at most three years, and no longer than your account exists.

10. Permissions the app asks for, and why

Android asks you for each of these separately. You can refuse any of them, and you can withdraw any of them later in your phone settings. Some parts of the app then stop working, but nothing else happens.

• Accessibility service. This is what makes the lock work. It tells Brainmute which app you just opened, so it can show the lock screen. Brainmute does not read the content of any screen and does not record anything you type in other apps.
• Usage access. So that the lock knows which app is in front of you and locks it again on time when your unlocked time runs out. This information stays in your phone's memory and is not transmitted.
• Display over other apps. To draw the lock screen on top of the app you tried to open.
• Physical activity. To read your step count for movement missions.
• Notifications. To show you countdowns and reminders. All notifications are created on your device.
• Run at startup and ignore battery optimisation. So the lock still works after you restart your phone and is not shut down by the system.

11. Email contact and routing

Emails to support@brainmute.app are received and stored in a mailbox at IONOS SE (Elgendorfer Straße 57, 56410 Montabaur, Germany) in order to process your request. IONOS acts as our processor pursuant to Art. 28 GDPR; the applicable data processing agreement forms part of the IONOS General Terms and Conditions. Processing takes place within the European Union (primarily in Germany). To our current knowledge, there is no transfer of personal data to a third country. Data processed: sender address, recipient address, subject, message content, attachments and headers.

If you use the contact us entry in the app (tap your profile picture in the top right, the entry is in the first menu), the app opens a draft email in your own email program. The recipient, the subject and a few technical lines are pre-filled: the version of the app, your Android version and your device model (for example SM-A566B). These lines help us reproduce a problem on the right kind of device. They contain no unique device identifier, in particular no advertising ID, no serial number and no IMEI, and no location data. The same contact us also appears on the screen the app shows when one of its pages runs into an error. There, the draft additionally contains one line with the name and the message of that error, shortened to 180 characters, so that we can see what went wrong. The app does not transmit anything by itself; the draft is only sent once you send it, and you can edit or delete these lines beforehand.

Legal basis: Art. 6 (1) (b) GDPR (pre-contractual requests) or Art. 6 (1) (f) GDPR (legitimate interest in communication).
Storage period: until your request has been dealt with; statutory retention obligations, in particular commercial and tax retention periods, remain unaffected.
Provision of data: providing your data is voluntary; without your email address and the content of your message we cannot process your request.

12. Cookies, local storage and analytics

This site does not use cookies for analysis, marketing or tracking. There is no Google Analytics, no Meta pixel and no TikTok pixel.

Cloudflare may set one technically necessary cookie (__cf_bm, lifetime max. 30 minutes) for bot defence. Legal basis: § 25 (2) no. 2 TDDDG (strictly necessary) and Art. 6 (1) (f) GDPR.

This site does not use any web analytics or reach measurement, and it does not load any tracking scripts.

Because no analytics, marketing or tracking tools are used, this site does not require a cookie consent banner. If such tools are added in future, this policy will be updated and, where required, your consent obtained beforehand.

13. Transfers to third countries

Some of our providers are based outside the European Union, or can access personal data from there. Where data is transferred to a third country, we put in place the safeguards required under Chapter V GDPR. Here is who they are and what each transfer is based on.

• Supabase Pte. Ltd, Singapore runs our database and our sign-in. Your data is stored in the European Union region (Frankfurt, Germany, eu-central-1) and is processed there as a rule. In certain cases access from a third country may be necessary, in particular by support staff at Supabase, Inc. in the USA, which Supabase lists as a sub-processor for support services. There is no adequacy decision for Singapore, and none applies to Supabase, Inc. either: the company is not listed as a participant in the EU-US Data Privacy Framework (as at 9 September 2026). Both transfers are therefore based on the EU standard contractual clauses under Art. 46 (2) (c) GDPR (Commission Implementing Decision (EU) 2021/914). Supabase uses further technical sub-processors, for example for hosting, infrastructure and monitoring; Supabase keeps them in a public list.
• Cloudflare, Inc., USA provides our domain, our website and its security. Where the processing falls within the certified scope, it relies on the EU-US Data Privacy Framework (adequacy decision of 10 July 2023, Art. 45 GDPR); Cloudflare is listed there with the status Active. EU standard contractual clauses apply in addition, and Cloudflare relies on them should the certification lapse.
• Resend, USA sent the emails for your account until 12 September 2026. Since then we no longer transmit any data there; sending runs entirely through Scaleway in France (see section 8). Resend stores the data in the USA, even where sending ran through a European region. According to Resend, message and log data is kept there for 30 days and then deleted; any remaining data is deleted within 90 days of closing the account. The earlier transfer relies on the EU standard contractual clauses; in addition, Resend is certified under the EU-US Data Privacy Framework.
• RevenueCat, Inc., USA manages subscriptions. It receives your account ID, your purchase history from Google Play, the technical details of each connection such as your IP address, and the device details listed in section 9; no name, no email address and no advertising ID (see section 9). RevenueCat is not listed as a participant in the EU-US Data Privacy Framework; the transfer is based on the EU standard contractual clauses under Art. 46 (2) (c) GDPR.
• Google LLC, USA: the technical information from the Google Play Billing Library described in section 9 goes to servers of Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework and its UK Extension with the status Active; the transfer relies on the adequacy decision of 10 July 2023 (Art. 45 GDPR).

We have data processing agreements under Art. 28 GDPR with the processors we use. You can request a copy of the standard contractual clauses at support@brainmute.app.

14. Storage periods

We store personal data only as long as necessary for the respective purpose or as required by statutory retention obligations. Specific periods: server log files max. 14 days; the __cf_bm cookie max. 30 minutes; unconfirmed accounts max. 48 hours; accounts that are not used again after their first 24 hours 90 days, unless a subscription or free trial was started with them (section 8); the check values used to limit email requests max. two days; Supabase's technical logs with your IP address max. one day; the IP address and user agent of your sign-in until you sign out; the record of sent subscription emails max. three years (section 9); everything listed in section 7 for as long as your account exists, unless a statutory retention obligation, in particular under tax or commercial law, requires us to keep certain records for longer. You can delete your account at any time in the app itself: tap your profile picture in the top right, go to the ACCOUNT section and choose delete account at the very bottom. This deletes your account, everything listed in section 7 (including your subscription information) and your record at RevenueCat. If RevenueCat reports a subscription event after your account is deleted, we discard it. You can also ask us to do it by writing to support@brainmute.app.

For the emails about your account the following also applies: sending and delivery data at Scaleway is stored only for as long as it is needed to investigate delivery failures and to prove delivery. Blocklist entries remain for the periods stated in section 8. Log data at our former provider Resend is deleted according to the periods that apply there, see section 13.

15. Your rights

As a data subject you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR), in particular against processing based on legitimate interest, for reasons arising from your particular situation
• Right not to be subject to a decision based solely on automated processing (Art. 22 GDPR); this does not take place

To exercise your rights, an informal message to support@brainmute.app is enough.

16. Withdrawal of consent and objection

Where we process personal data on the basis of your consent, you can withdraw that consent at any time with effect for the future (Art. 7 (3) GDPR). This does not affect the lawfulness of processing carried out before the withdrawal.

Where we process personal data on the basis of legitimate interests, you can object under Art. 21 GDPR on grounds relating to your particular situation.

17. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example at the authority of your habitual residence or of our place of business:

18. Data security

We protect personal data with appropriate technical and organisational measures against unauthorised access, loss, alteration and disclosure. This site uses SSL/TLS encryption, recognizable by "https://" and the padlock symbol in your browser. The app also sends data to our servers and to RevenueCat only over encrypted connections (TLS). Access to the data on our servers is limited to the systems and persons who need it to run and secure the service. Data that stays on your phone is protected by Android, which keeps the storage of each app separate from other apps.

19. Minors

Brainmute is intended for persons aged 16 or over. The app asks for your age before you can use it. If we become aware that an account belongs to a person under 16, we delete it without delay.

Before you create an account, the app asks Google Play whether it has an age signal for your Google account (Play Age Signals). Google only provides one in some regions. If there is no age signal, which is the normal case outside those regions, the app continues and relies on its own question about your age. If Google reports that you are a minor without your parent's approval, or that your age still has to be confirmed, you cannot subscribe for now, and the app tells you why. The answer is only used in the app's memory at that moment. It is not stored and not sent to us. Google processes this information under its own responsibility. Legal basis: Art. 6 (1) (f) GDPR; our legitimate interest is to apply the age rules of Google Play and of the laws that apply to app stores, and to sell subscriptions only to people who are allowed to buy them.

20. Changes to this policy

We may adapt this policy when the legal situation or the actual data processing changes (for example when new services are integrated). The version published at brainmute.app/privacy-policy applies.