Privacy
Policy

Last updated: August 2026

1. Introduction

This Privacy Policy explains how Neurotren (the “App”), operated by Oksana Omelchenko, Sole Proprietor in Kyiv, Ukraine, and our website at neurotren.com (the “Site”) collect, use, store, and share personal data.

By using Neurotren, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Services.

You may contact us at privacy@neurotren.com with any questions about data protection.

2. Data We Collect

2.1. Account Data

• Email address and/or name (via Firebase Authentication — Email/Password, Google Sign-In, or Sign in with Apple)
• An anonymous device-linked identifier, if you use the App without creating an account

2.2. Activity Data

• Your daily exercise completion history and streak
• Your progress across exercise categories (Neuro, Focus, Memory, Creativity, Awareness)

2.3. Onboarding Self-Assessment Data

During onboarding, we ask a small set of self-report questions, including your self-reported frequency of AI tool use, your confidence performing tasks without them, and how often you try new things or experience routine in your day-to-day life.

This category of data is explicitly self-reported and is not a clinical, psychological, or diagnostic assessment. It is used only to personalize your in-app content and is treated with the same care as other account data described in this Policy.

2.4. Social / Friends Data

If you connect with other users via a referral or invite code, we store the connection and limited activity status (e.g., whether a daily exercise was completed, current streak) that is visible only to friends you have explicitly accepted.

2.5. Automatically Collected Data

• Device information (model, OS version, limited device identifiers)
• App usage and interaction data (via PostHog)
• Crash and error diagnostic data (via Sentry)
• Push notification tokens

2.6. Payment Information

All payment and subscription data is processed by the Apple App Store and RevenueCat. Neurotren does not store or have direct access to your credit card or full payment details.

2.7. Website Data

If you sign up for our waitlist or newsletter on neurotren.com, we collect your email address. The Site may also collect analytics data as described in our Cookie Policy.

3. How We Use Your Data

We use your data to:

• provide and personalize daily and rotating exercises;
• maintain your completion history, streaks, and social/friends features;
• process subscriptions and purchases;
• send push notifications you have opted into (reminders, friend activity pings);
• diagnose crashes and improve app stability and performance;
• understand aggregate usage patterns to improve the App.

We do not use your personal data to train third-party or proprietary AI models. We do not sell or rent your personal data for marketing purposes. Neurotren does not use any AI-generation feature to produce content shown to users.

We use aggregate, anonymized activity data from other users to generate percentile-based engagement summaries (e.g., weekly consistency comparisons in your “Weekly Wrapped”). This never reveals other users’ individual data to you.

4. Cognitive Debt Score — How It’s Calculated and Why It’s Isolated

The in-app “Cognitive Debt Score” and related metrics are calculated exclusively from your self-reported onboarding answers, and are intentionally kept separate from your exercise completion data. We do this so that your engagement with the App (how often you complete exercises) cannot influence, or be influenced by, a self-assessment-style score — consistent with FTC guidance regarding health and cognitive-improvement claims in this product category. This score is not a clinical measurement and should not be treated as one (see Section 3 of our Terms of Service for the full disclaimer).

5. Third-Party Services

Neurotren relies on the following service providers, each of which processes data under its own privacy policy:

5.1. Firebase (Google)

Authentication, Firestore database, Cloud Functions
firebase.google.com/support/privacy

5.2. RevenueCat

Subscription and purchase management
revenuecat.com/privacy

5.3. PostHog

Product analytics
posthog.com/privacy

5.4. Sentry

Crash and error reporting
sentry.io/privacy

5.5. Apple App Store

Billing, subscription renewals, refunds

6. iOS Permissions Disclosure

6.1. Push Notifications (Optional)

Used for exercise reminders and friend activity pings. You may disable notifications at any time in your device settings.

No data from device permissions is used for advertising or cross-app tracking.

7. Legal Basis for Processing (GDPR)

If you are located in the EU/EEA, we rely on:

• Contract performance — to provide the App and its core features;
• Consent — for optional features such as push notifications and friends/social features;
• Legitimate interest — to maintain, secure, and improve the Services.

You may withdraw consent for optional features at any time through in-app settings.

8. Data Storage & Retention

Your data is stored securely in Firebase (Google Cloud). We retain your data for as long as your account is active, or as needed to provide the Services, and delete or anonymize it upon a verified deletion request or after a period of account inactivity.

You may request deletion of your data at any time directly within the App via Profile → Delete Account (or Delete Guest Data for anonymous users). This immediately and permanently deletes your streak, progress, category statistics, and account data. You may also contact privacy@neurotren.com with deletion-related questions.

9. Your Rights

Depending on your location, you have the right to:

• access your data;
• request correction or deletion;
• withdraw consent;
• export your data (if supported);
• object to or restrict certain processing.

Contact privacy@neurotren.com to exercise these rights.

10. Data Sharing & Security

We share data only with the service providers listed in Section 5. We use industry-standard security measures, including encryption in transit (HTTPS/TLS) and access controls on our databases; however, no system can be guaranteed to be fully secure.

We do not use third-party advertising SDKs and do not share data for cross-app advertising or tracking purposes.

11. Children’s Privacy

Neurotren is intended for users 16 years of age and older (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from individuals below this age. If we learn that we have collected data from someone below the applicable minimum age, we will delete it promptly. Parents or guardians who believe we may have collected such data should contact privacy@neurotren.com.

12. International Transfers

Data may be processed outside your country of residence due to our use of Firebase, RevenueCat, PostHog, and Sentry, each of which may operate infrastructure in the United States or other jurisdictions. Where applicable, we rely on GDPR-compatible transfer mechanisms such as Standard Contractual Clauses, as implemented by these providers.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes become effective once posted at neurotren.com/privacy.