Natural Privacy Notice

Brain Technologies, Inc.

Last Updated: March 22, 2026

This Privacy Notice applies to the processing of personal information by Brain Technologies, Inc. (“Brain,” “we,” “us,” or “our”) in connection with Natural, our AI-powered mobile operating system, applications, and related services (collectively, the “Services”).

Natural is designed to provide users with an AI-native mobile experience, including features that enable interaction with content, applications, and services across the device. This Privacy Notice describes how we collect, use, disclose, and retain personal information when you use Natural and any associated services that link to or reference this Privacy Notice.

IMPORTANT NOTICE REGARDING DATA COLLECTION AND USE:

By using our Services, you explicitly acknowledge and agree to the data collection, usage, and retention practices detailed in our Privacy Notice. This includes the collection of your screen recordings, audio recordings, interactions with your device and the potential review and use of data associated with these interactions by Brain to provide and improve the Services.

IF YOU DO NOT AGREE WITH THE DATA PRACTICES OUTLINED IN THIS PRIVACY NOTICE, DO NOT ACCESS OR USE OUR SERVICES. DO NOT USE OUR SERVICES FOR ANY ACTIVITIES OR WITH ANY INFORMATION YOU CONSIDER PRIVATE, CONFIDENTIAL, OR THAT YOU DO NOT WISH TO BE SAVED OR REVIEWED BY BRAIN.

Disclosure Regarding the Use of the Google API Services. If you choose to sign into your Brain account using your Google account, then Brain will obtain access to your Google calendar and email information via the Google API Services to provide you with certain functionalities of the Services (e.g. scheduling meetings and drafting emails on your behalf). Brain’s receipt, use and transfer to any other application of your Google user information received from the Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use Requirements, as described in further detail in the “Limits on Use of Your Google and YouTube User Data” section below.

1. UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE SHARE PERSONAL INFORMATION
5. PRODUCT-SPECIFIC INFORMATION
6. YOUR PRIVACY CHOICES AND RIGHTS
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
8. CHILDREN'S PERSONAL INFORMATION
9. CONTACT US

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Information. We may collect personal information in connection with the creation or administration of your account to register your device. This personal information may include, but is not limited to, your email address, phone number, and other information you store with your account.
Mobile Device Data: When you use our Services, you will need to allow Brain to access your entire phone to allow us to provide you with Brain’s AI mobile capabilities. You agree that Brain may access any data or mobile applications on your device, including your login credentials, that you instruct it to use through voice commands.
Purchase Information. We may collect personal information and details associated with your purchases on the Services, including payment information when the Services take an action on your behalf (e.g., to place an order for goods or to purchase airline tickets, hotel stays, or rental cars). Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Screen and Voice Data: If you use the Services, we, and our service providers, may collect the following information if you choose to provide us with access or permission:

Screen Recordings: We will request access or permission to capture screenshots of your screen in order to provide you with the Services. During an active session, screenshots of your device’s screen content are shared with our servers or service providers. This screenshot may capture any information visible on your screen. PLEASE DO NOT PROVIDE OR ENTER SENSITIVE PERSONAL INFORMATION (SUCH AS CREDIT CARD OR ACCOUNT NUMBERS, SOCIAL SECURITY NUMBERS, OR HEALTH AND MEDICAL INFORMATION) WHILE A SESSION ON YOUR DEVICE IS ACTIVE. If you wish to change our access or permissions to your screen, you may do so in your device's settings.

Audio Recordings: We may request access or permission to record your voice and other audio to provide our “Press to Speak” feature. During an active session, audio from your device's microphone is continuously streamed to our servers or service providers and recorded. This includes your voice commands and any ambient sounds captured by the microphone. PLEASE DO NOT PROVIDE OR ENTER SENSITIVE PERSONAL INFORMATION (SUCH AS CREDIT CARD OR ACCOUNT NUMBERS, SOCIAL SECURITY NUMBERS, OR HEALTH AND MEDICAL INFORMATION) WHILE A SESSION ON YOUR DEVICE IS ACTIVE. If you wish to change our access or permissions, you may do so in your device's settings.
Google User Data: When you connect your Google account to our Services, we will access your Google user data (“Google User Data”). You have control over what Google User Data you permit us to access. For example, Google Calendar permissions include access to your calendar, calendar events, calendar lists, and calendar settings. You can revoke our access to your Google User Data at any time. Personal data from connected services (such as email and calendar, including Google User Data) is only accessed and processed when you explicitly initiate an action within the Services (e.g., searching, viewing, or interacting with content). We do not access or process such data in the background without user action.
YouTube Data. If you use the Services to interact with YouTube content, we may access, collect, and store information such as video metadata, playlists, and channel information via the YouTube API Services to provide the requested functionality. Our Services utilize YouTube API Services, and by using these Services, you agree to be bound by the Google Privacy Policy (https://www.google.com/policies/privacy). You may review how Google uses data at that link.
Your Communications with Us. We, and our service providers, may collect the information you choose to communicate to us, such as through your email communications with Brain, including interactions with customer support and contacts through social media channels.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings for any device you use to access to the Services, cookie identifiers, IMEI number and other unique device identifiers (such as the mobile country code, mobile network code, MAC address, serial number, device unique IDs, advertising ID, browser or device information, Internet service provider, and location information (including, as applicable, an approximate location derived from the IP address and precise geo-location information)).
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
Location Information. We may collect information about nearby Wi-Fi access points, cell towers, and, with your separate consent, precise geolocation, may be transmitted to us when you use certain Services.
Third-Party Cookies and Device Storage. YouTube API Services may store, access, or collect information directly or indirectly on or from your device, including by placing, accessing, or recognizing cookies or similar technology on your device or browser."

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a third-party website, application, service, products, or technology (each a “Third-Party Service”), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to provide the Services, such as:

Providing access to certain areas, functionalities, and features of the Services;
Helping you register your device with us to receive the Services;
To verify your device for repairs;
To provide software updates, maintenance services, and support for your devices;
Communicating with you;
Answering requests;
Sharing personal information with third parties as needed to provide the Services; and
Processing your financial information and other payment methods.

Limits on Use of Your Google and YouTube User Data

To the extent that any Google or YouTube User Data to which you provide us access to constitutes personal information under this Privacy Notice, it will be subject to the provisions of this Privacy Notice. Notwithstanding anything else in this Privacy Notice, if you provide us with access to Google or YouTube User Data, our use of that data will be subject to these additional restrictions:

The Google User Data will be used only to provide or improve user-facing features that are prominent in our user interface.
The Google User Data will be transferred to others only as necessary to provide and improve these user-facing features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
The Google User Data will not be used for serving advertisements.
The Google User Data will be read by humans only in the following cases:
- As part of the user interface, as controlled by your Brain privacy settings;
- If we obtain your affirmative agreement to view specific data from your account;
- If it is necessary for security purposes (such as investigating a bug or abuse);
- If it is necessary to comply with applicable law; and
- As necessary for internal operations, provided that the data has been aggregated and anonymized.

For clarity, the following practices are prohibited with respect to Google and YouTube User Data:

Google User Data will not be sold to third parties.
Google User Data will not be used to develop, train, fine-tune, or improve generalized AI or machine learning models.
Google User Data will not be used to serve advertisements or for advertising-related profiling.
Google User Data will not be retained longer than necessary to provide the user-facing features you have requested, unless retention is required by law.

B. Improve the Services and Develop New Products and Services

We use personal information to improve the Services and to develop new products and services, including:

Developing, training, and fine-tuning models, algorithms, and artificial intelligence technologies; and
Improving, upgrading, or enhancing the Services.

You agree that Brain and its service providers may use your personal information (excluding Google User Data, as described below) to train on and fine-tune models to provide and improve the Services.

Google User Data Exclusion: Notwithstanding the foregoing, Google User Data (including data obtained from Gmail, Google Calendar, and YouTube API Services) is never used for developing, training, fine-tuning, or improving any artificial intelligence or machine learning models. Google User Data is processed solely to provide and improve the specific user-facing features you request through the Services, in strict compliance with the Google API Services User Data Policy, including the Limited Use Requirements.

C. Operate Our Business

We use personal information to operate our business, such as:

Carrying out analytics;
Creating de-identified and/or aggregated information;
To ensure product safety and prevent fraud;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

D. Marketing

We may use personal information in connection with our marketing activities, including to tailor and provide you with marketing communications, promotions, and offers that may interest you. Google User Data is not used for marketing or advertising purposes.

E. With Your Consent or Direction

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

F. To Make Recommendations and Personalization

We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with our Services.

4. HOW WE SHARE PERSONAL INFORMATION

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be shared with service providers that help provide our chat features. Some of the service providers we may use include:
- Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt out of Google Analytics’ use of your personal information, please click here.
Human Reviewers. Your personal information (such as screen recordings and audio recordings) may be accessed and reviewed by authorized Brain personnel solely for the purpose of providing, maintaining, and improving the Services, including debugging, quality assurance, and user support. Human access to Google User Data is strictly limited to the cases described in the "Limits on Use of Your Google and YouTube User Data" section and only with user consent or as required for security or legal purposes.
Other Users You Share or Interact With. The Services may allow Brain users to share personal information or interact with other users of the Services.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service. Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share your personal information with business partners we work with to provide you with a product or service you have requested. For example, we may share your personal information with the following business partners: wireless carriers, ad partners or marketing partners from whom you choose to request services or content of interest to you. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
Affiliates. We may share your personal information with our corporate affiliates.

B. Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

5. PRODUCT-SPECIFIC INFORMATION

Camera: When you permit an application to access the device camera, the application may capture real-time photos and videos from the front and/or rear cameras. Photos and videos may include other information such as the time, date, and location of capture. You can manage or revoke camera access, as well as control what information is stored with media files, in your device’s settings. Access granted to one application does not grant access to other applications.
Weather Application: If you use the weather application (“Weather”), you may choose to share your precise geolocation information to receive local forecasts and alerts. You can manage location permissions in your device's settings.
- If you allow Weather to access your location, your location will be sent to Brain to provide relevant weather forecasts. Your location is not associated with your identity.
- If you request a forecast for a saved or followed location, that information will be sent to Brain to provide a forecast for that location. This is not associated with your identity.
- If you enable severe weather notifications, Brain can associate the region of such notifications with your account.

6. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Notice).
Mobile Devices. We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to Our Processing of Your Personal Information;
Request to Opt Out of Certain Processing Activities, including, as applicable, if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and
Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

Data Protection Safeguards. We implement appropriate technical and organizational measures to protect personal information, including Google User Data, against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of personal information in transit (TLS) and at rest;
Access controls that restrict access to personal information to authorized personnel with a legitimate business need;
Logging and monitoring of access to sensitive data, including Google User Data;
Contractual protections with service providers that process personal information on our behalf, requiring them to maintain appropriate security measures; and
Regular review of our data collection, storage, and processing practices.

Google User Data is stored and processed in accordance with the Google API Services User Data Policy, including the Limited Use Requirements, and is subject to the access restrictions described in the "Limits on Use of Your Google and YouTube User Data" section above.

8. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

9. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at: support@brain.im.