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Privacy Policy — NeuralMind

Effective Date: July 19, 2026 Last Updated: October 9, 2026


1. Data Controller

Cheval-Volant LLC (operating as NeuralMind) Operator: Darren Frost (dfrostar) Email: hello@neuralmind.uk Location: Texas, USA

For all inquiries regarding this Privacy Policy or your personal data, contact: hello@neuralmind.uk


2. Data We Collect

2.1 Data You Provide

2.2 Data Collected Automatically

There is no license portal yet: licenses are issued manually and sent to you directly. No portal records your IP address or user agent, and no payment-processor customer ID is stored.

2.3 Data We Do NOT Collect


3. Legal Basis for Processing (GDPR Article 6)

We process your personal data under the following legal bases:

Purpose Legal Basis
License issuance and renewal Performance of contract (6.1.b)
Audit logging (actor, action) Legitimate interest — fraud prevention, security, dispute resolution (6.1.f)
Billing (manual invoicing) Performance of contract (6.1.b)
Customer support Performance of contract (6.1.b)
GDPR/similar regulation compliance Legal obligation (6.1.c)

For users in the EU/EEA: You have the right to object to processing based on legitimate interest. Contact hello@neuralmind.uk to discuss.


4. Why We Process Your Data

Data Purpose
Email License identification, renewal reminders, security alerts
Company name License attribution (optional)
License metadata License validation, renewal processing

We do NOT use your data for marketing without separate consent.


5. Data Retention

Data Category Retention Period
Active license data Duration of license + 3 years after expiry
Audit logs 3 years after creation, then anonymized
Financial records 7 years (required for tax compliance)
Deleted customer records Anonymized immediately; financial records retained per above

After the retention period, we anonymize (not delete) financial records to comply with tax law, and delete personal data entirely.


6. Third-Party Processors (Sub-Processors)

We use the following processors to deliver our service:

Processor Data Accessed Purpose DPA Available
GitHub Username (via GitHub login, if used) Community forum, issue tracking https://docs.github.com/en/site-policy

No payment processor or invoicing service is integrated: Team licenses are invoiced manually, in USD, and invoices are sent by email.

We do not sell your data, share it with third parties for their own purposes, or use it for advertising. Email you send us is held by our business email provider, as with any business email.

If a new sub-processor is added, we will update this Policy and notify existing customers via email 30 days before the new processor begins processing.

Scope note: this section covers data collected by NeuralMind’s own commercial operations (license issuance, billing). It does not cover the runtime behavior of the OSS tool running against your codebase — that is documented separately in compliance/THIRD_PARTY_LLM_DISCLOSURE.md, including the one opt-in path where the OSS tool itself calls a third-party LLM (Anthropic), disabled by default.


7. International Data Transfers

Your data is processed in the United States (where we operate). For EU/EEA residents:

We will migrate to EU-hosted infrastructure if EU revenue becomes a significant portion of total revenue.


8. Your Rights (GDPR Articles 15-22)

You have the right to:

  1. Access — Receive a copy of your personal data
  2. Rectification — Correct inaccurate data
  3. Erasure (“right to be forgotten”) — Request deletion of your personal data
  4. Restriction — Request we limit processing in certain circumstances
  5. Portability — Receive your data in a structured, machine-readable format
  6. Object — Object to processing based on legitimate interests
  7. Withdraw consent — Where processing relies on consent, withdraw at any time

To exercise any right: Email hello@neuralmind.uk. We respond within 30 days.

Deletion process:

  1. We verify your identity
  2. We delete your Customer record
  3. We anonymize (not delete) LicenseIssuance records — financial/tax records must be retained
  4. We delete AuditLog entries containing your personal data
  5. We confirm completion via email

Exception: Financial records (license hash, signature, transaction amount) are retained in anonymized form for 7 years per US tax law (26 USC 6501).


There is no license portal yet, so licensing sets no cookies.

We do NOT use analytics cookies, advertising cookies, or social media cookies. No cookie consent banner is required because we set no cookies.

If we add analytics in the future, we will update this Policy and implement a cookie consent mechanism.


10. Security

We implement the following security measures:

We will notify affected customers within 72 hours of becoming aware of a personal data breach, as required by GDPR Article 33.


11. Children’s Privacy

NeuralMind is a developer tool. We do not knowingly collect data from anyone under 16. If you believe a child under 16 has provided personal data, contact hello@neuralmind.uk for immediate deletion.


12. Changes to This Policy

We may update this Policy to reflect legal, technical, or business changes. We will:

Non-material changes (clarifications, formatting) take effect on posting.


13. Contact

Data Controller: Cheval-Volant LLC / NeuralMind Email: hello@neuralmind.uk GitHub: https://github.com/dfrostar/neuralmind Response time: Within 72 hours for data inquiries; 30 days for formal rights requests

Right to lodge complaint: If you are in the EU/EEA and believe we have violated your rights, you have the right to lodge a complaint with your local Data Protection Authority.


14. Terms of Service

This Policy works in conjunction with our Terms of Service. Together they form the basis for how we handle your data and your rights and obligations as a customer.


This Privacy Policy is for informational purposes and is not legal advice. Consult a qualified attorney for legal advice specific to your jurisdiction.