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How we collect, use and protect your personal data.
Effective Date: June 16, 2026
Last Updated: June 16, 2026
Minds Pulse (the “App”) is a product of the MINDSMLM platform, operated by BRAVON S.à R.L., a company registered in Luxembourg with its registered office at 9, Rue Basse, L-4963 Clémency, Luxembourg (“we”, “us”, “our”). BRAVON S.à R.L. is the data controller responsible for your personal data under the EU General Data Protection Regulation (GDPR).
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the App.
When you create an account or use the App, we collect only the following account information:
•Name
•Email address
•Phone number (optional)
You may choose to import business data into the App, either by uploading an Excel (.xlsx) file or by connecting your existing Bravon MINDS account:
•Contact lists and network/CRM data
•Sales pipeline data, deal information, and revenue figures
This data is provided by you and remains under your control. See Section 12 regarding data about other individuals.
When you use the App, we automatically collect:
•Device information (model, OS version, unique device identifiers)
•App usage data (features used, session duration, navigation patterns)
•In-app purchase history
•Crash reports and performance data
•IP address and approximate location (country/region level only)
When you interact with Pulse AI features, we collect:
•Chat messages and queries you send to the AI
•AI-generated responses and recommendations
•Feature usage patterns for AI services
We process your information for the purposes below. For each purpose we rely on the GDPR legal basis indicated (Article 6):
•Provide and maintain the App and its features — performance of our contract with you (Art. 6(1)(b)).
•Process in-app purchases and manage subscriptions — performance of a contract (Art. 6(1)(b)) and legal obligation (Art. 6(1)(c)).
•Deliver AI-powered coaching, recommendations, analytics, and scores (performance scores, NHI, Data Confidence) — performance of a contract (Art. 6(1)(b)); for sending business data to our AI provider we also rely on your consent (Art. 6(1)(a)), obtained via the in-app AI consent screen described in Section 3.
•Send transactional notifications (purchase confirmations, account updates) — performance of a contract (Art. 6(1)(b)).
•Improve the App through anonymized analytics, security, and fraud prevention — our legitimate interests (Art. 6(1)(f)).
•Provide customer support — performance of a contract and our legitimate interests (Art. 6(1)(b), (f)).
•Comply with legal obligations — legal obligation (Art. 6(1)(c)).
We do not sell your personal information, and we do not use your business data for advertising.
Our AI features are powered by a third-party AI provider, Anthropic, PBC (Claude API), located in the United States. To generate insights, coaching, analytics, and reports, the App sends relevant data to Anthropic for processing.
Depending on the feature you use, the data sent for AI analysis may include imported business data (such as contact records, sales figures, pipeline data) and the chat messages you submit to the AI.
Before transmitting data to the AI provider, we minimise and, where feasible, pseudonymise personal identifiers — for example, we remove email addresses and phone numbers and truncate member names (e.g. first name + last initial), and we aggregate data into counts where possible. This reduces the personal data exposed to the AI provider.
•Your data is not used to train AI models.
•AI processing logs are retained for 90 days for service quality and security, then anonymized.
Before your imported or synced data is sent to the AI provider, the App displays an in-app notice that identifies the AI provider (Anthropic / Claude) and what is sent, and asks you to review and accept. You can decline, and you can stop using AI features at any time. You can also review what is sent and to whom in this Privacy Policy and in the in-app AI notice.
Your account and business data are stored on secure servers located in the European Union (Amazon Web Services, Frankfurt / eu-central-1 region), in compliance with GDPR. AI processing additionally involves a transfer to the United States — see Section 6.
We implement technical and organisational measures appropriate to the risk (GDPR Art. 32), including:
•Encryption in transit (TLS 1.3) and at rest (AES-256)
•Access controls and authentication
•Regular security reviews
•Automated backups
•Breach notification procedures (notification to the supervisory authority within 72 hours where required)
•Account data: retained while your account is active and for up to 30 days after a deletion request.
•Business data: deleted within 30 days of account deletion or upon your request.
•AI interaction logs: retained for 90 days, then anonymized.
•Payment records: retained as required by applicable tax and financial regulations (typically up to 10 years under Luxembourg law).
We do NOT sell your personal information. We share data only with the categories of recipients (sub-processors) below, under contractual data-protection obligations:
•Cloud hosting — Amazon Web Services EMEA (EU-based infrastructure, Frankfurt).
•AI processing — Anthropic, PBC (Claude API, United States). Data is not used for model training.
•Payment processing — Apple App Store (Apple Inc.) and Google Play (Google LLC). We do not receive or store your payment card details.
•Analytics and crash reporting — used in anonymized / aggregated form to improve the App. [VERIFY: list the specific providers used, e.g. Firebase Analytics / Crashlytics, in your App Store / Play Data Safety declarations.]
•Legal requirements — we may disclose information if required by law, regulation, legal process, or a valid governmental request.
•Business transfers — in a merger, acquisition, or sale of assets your data may be transferred; we will notify you of any such change.
When data is processed by our AI provider (Anthropic, PBC) it is transferred to the United States. Such transfers are protected by the European Commission’s Standard Contractual Clauses (SCCs) together with supplementary technical measures, including the data minimisation and pseudonymisation described in Section 3. You may request a copy of the relevant safeguards using the contact details in Section 14.
As a data subject in the EU, you have the right to:
•Access — request a copy of your personal data.
•Rectification — correct inaccurate personal data.
•Erasure — request deletion of your personal data (“right to be forgotten”).
•Restriction — restrict processing of your personal data.
•Portability — receive your data in a structured, machine-readable format.
•Objection — object to processing based on legitimate interests.
•Withdraw consent — withdraw consent at any time, without affecting the lawfulness of prior processing.
To exercise these rights, contact us at privacy@mindsmlm.com. We will respond within 30 days, as required by GDPR.
You also have the right to lodge a complaint with your local supervisory authority. In Luxembourg this is the Commission Nationale pour la Protection des Données (CNPD) — cnpd.public.lu.
You can delete your account at any time directly in the App (Settings → Account → Delete Account), without contacting support. Deleting your account removes your account and associated business data within 30 days, except data we must retain to meet legal obligations (e.g. transaction records). Deletion can also be requested at support@mindsmlm.com.
All payments are processed through the Apple App Store or Google Play. We do not collect or store payment card information.
•Pulse Pass (€14.99/month) is an auto-renewable subscription.
•Credit packs (Pulsys) are one-time purchases.
•Manage or cancel subscriptions through your device’s app store settings.
The App is not intended for children under 16. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal data, we will take steps to delete it.
You can bring your business data into the App in two ways: (1) by uploading an Excel (.xlsx) file, or (2) by connecting your existing Bravon MINDS account, which lets you sync data you already hold in the MINDS platform. We access only the data necessary to provide our features. We may add further CRM connectors in the future; if we do, we will update this Policy and access only the data needed, using secure tokens you can revoke at any time.
Where you import personal data about other individuals (such as contacts), you confirm you have a lawful basis to process and share that data with us and our sub-processors, and that you have informed those individuals as required by law. We process such data on your behalf solely to provide the App’s features.
The mobile App does not use cookies. We use minimal, anonymized analytics to improve the user experience. You can opt out of analytics in the App settings.
We may update this Privacy Policy periodically. We will notify you of material changes through the App or via email. Continued use after changes take effect constitutes acceptance.
Data controller:
BRAVON S.à R.L.
9, Rue Basse, L-4963 Clémency, Luxembourg
Product: mindsmlm.com · Company: bravon.io
Privacy / data-protection requests: privacy@mindsmlm.com
General / support: info@mindsmlm.com · support@mindsmlm.com
Company contact: info@bravon.io
This Privacy Policy is published at portal-pulse.mindsmlm.com/privacy-policy.