This policy explains what personal data New Brain collects, why, who we share it with, and the choices you have. New Brain is run by [Company legal name], a company registered in India ("we", "us"). It applies to trynewbrain.com, the New Brain web, desktop and phone apps, the connection your AI tools use, and the New Brain Card waitlist.
We wrote it in plain English. If anything is unclear, email info@trynewbrain.com.
1. The short version
- You own what you put in New Brain. We use it to run New Brain for you, and for nothing else.
- We never use your content to train AI models, ours or anyone else's.
- We never sell your personal data.
- You can export or delete your data at any time. A deleted brain is gone from our systems, backups included, within 30 days.
2. What we collect
Account details. Your name, email address, and how you sign in (email, Google, Microsoft, Apple or your company's single sign-on). For a company brain, your role and the areas you can see.
Your content. What you save or bring into New Brain: notes, decisions, files, links, voice notes, recordings and their transcripts, and the content of apps you connect (for example Notion pages, Google Drive files, Gmail threads, Slack messages, Jira issues and GitHub items). We only bring in what you choose when you connect an app.
What your AI tools send. When you connect an AI tool such as ChatGPT or Claude, that tool sends New Brain the questions it looks up and the things it saves on your behalf.
Usage and device data. Which features you use, how many questions and recording hours you use, the times AI tools read or saved, your browser and device type, IP address, and error logs. We use this to run the service, enforce plan limits, keep it secure and fix problems.
Payment details. When you buy a paid plan, our payment provider collects your card details. We receive only what we need for billing, such as your billing name, country and the last digits of your card.
Messages and forms. What you send us by email, and what you enter in our forms, such as a notify-me email or the New Brain Card waitlist (email, phone type, country and what you'd record).
Website analytics. On trynewbrain.com we use PostHog, hosted in the EU, to see how the website is used: which pages are visited, which buttons are clicked, which waitlist or notify-me list someone joins (with the Card waitlist answers about phone type, country and what you'd record), the page that sent you here, and your browser and device type. It sets no cookies and stores nothing in your browser. To count visitors without a cookie, PostHog turns your IP address and browser details into a scrambled code that changes every day. It doesn't keep your IP address or look up your location. We never send PostHog your name or email address. If your browser sends a Do Not Track signal, the analytics don't load at all.
People in your content. Your content may include other people's personal data, such as names in emails or voices in a recording. You decide what goes into New Brain, and you are responsible for having the right to put it there, including getting consent before you record anyone.
3. How we use it
- To provide New Brain: store your content, answer questions with sources, let the AI tools you connect read and save, transcribe recordings, and keep your apps in sync.
- To run your account: sign-in, billing, plan limits, support and service emails.
- To keep New Brain secure: detect abuse, investigate problems, and keep activity logs.
- To improve New Brain: using usage data and, only with your permission, specific examples you choose to share with us.
- To tell you about New Brain: product news, if you agreed to it. You can unsubscribe at any time.
- To meet legal obligations.
AI models. To answer questions and process recordings, we send the relevant parts of your content to AI model and speech-to-text providers that work for us. They may only use it to provide that service to us, and they may not use it to train their models.
No training. We never use your content to train AI models.
4. Legal basis
Under India's Digital Personal Data Protection Act, 2023, we process your personal data with your consent, which you give when you create an account, connect an app or fill in a form, and for legitimate uses the Act allows. You can withdraw consent at any time; this stops the related processing from then on.
If you are in the European Economic Area or the United Kingdom, we rely on: performing our contract with you (running New Brain), our legitimate interests (security, fixing problems, improving the service, and counting website visits without cookies), your consent (marketing emails), and legal obligations.
5. Who we share it with
We share personal data only with service providers that help us run New Brain, under contracts that limit their use of it to that work:
- Hosting and databases
- Sign-in and single sign-on
- AI model and speech-to-text providers
- App connection services (to link Notion, Google Drive, Gmail, Slack, Jira and GitHub)
- Payments
- Email delivery
- Website analytics (PostHog, hosted in the EU)
[TODO: publish the named list of service providers (sub-processors) and their locations before launch. Planned, from the build docs: WorkOS (sign-in), Anthropic (AI model), Voyage AI (search), AssemblyAI and Deepgram (speech-to-text), Nango (app connections), Stripe (payments), Hostinger (email), PostHog (website analytics, EU), and the hosting provider. Confirm each.]
The AI tools you connect are not our service providers. When you let ChatGPT, Claude or another AI tool read from New Brain, what that tool does with the answer is governed by its own terms and privacy policy.
We may also share data if the law requires it, to protect people's safety, or as part of a merger or sale of the business, in which case this policy continues to apply.
We do not sell personal data, and we do not share it for advertising.
6. Google data
If you connect Gmail or Google Drive, our use of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements. We use Google data only to provide New Brain's features you asked for, never for advertising, and people at New Brain don't read it unless you ask us to, it's needed for security, or the law requires it.
7. Where your data is stored
We store data in the United States or the European Union. Business customers choose the location when they create a brain. [TODO: confirm hosting locations and the default region for Free, Pro and Team.] Because we are based in India and use service providers in other countries, your data may be processed outside your country. Where the law requires it, we use safeguards such as the European Commission's standard contractual clauses.
8. How long we keep it
- Your content: until you delete it or delete your account.
- When you delete your brain or account, we remove the data from our systems, backups included, within 30 days.
- Older history on the free plan is hidden from view, not deleted.
- Recordings: [TODO: set how long original audio is kept after transcription.]
- Billing records: as long as tax and accounting law requires.
- Notify-me and waitlist emails: until the product you asked about launches, or until you unsubscribe.
- Website analytics: [TODO: set how long PostHog keeps website events.]
- Security logs: [TODO: set period, e.g. 12 months.]
9. How we protect it
Data is encrypted in transit and at rest. Your original files, recordings, transcripts and raw app content are also encrypted with a key specific to your brain, which we destroy when you delete the brain. Each customer's data is kept apart at the database level. Access by our staff is limited to what's needed and is logged. No system is perfectly secure; if a breach affects your personal data, we will tell you and the authorities as the law requires.
10. Your rights
Wherever you are, you can:
- get a copy of your data (you can also export it yourself from Settings),
- correct it,
- delete it,
- withdraw consent you gave us,
- unsubscribe from marketing emails.
In India, under the Digital Personal Data Protection Act, 2023, you can also ask for a summary of the personal data we process and who we've shared it with, raise a grievance with our Grievance Officer, nominate someone to use your rights if you die or become unable to, and complain to the Data Protection Board of India if we don't resolve your grievance.
In the EEA and UK, you can also object to or restrict some processing, ask for your data in a portable format, and complain to your local data protection authority.
In California and other US states with privacy laws, you have similar rights to know, correct and delete. We don't sell or share personal data for targeted advertising.
To use any of these rights, email info@trynewbrain.com with "Privacy" in the subject. We may need to confirm your identity first. We will reply within the time the law sets.
11. Grievance Officer
[Grievance Officer name]
[Company legal name], [Registered address]
Email: info@trynewbrain.com [TODO: consider a dedicated privacy@ address]
12. Children
New Brain is not for anyone under 18, and we don't knowingly collect their personal data. If you believe a child has given us personal data, email us and we will delete it.
13. Cookies
See our cookie policy.
14. Changes to this policy
If we make a significant change, we'll email account holders and update the date at the top before the change takes effect.
15. Contact
[Company legal name]
[Registered address]
info@trynewbrain.com