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Privacy Policy

Last Updated: January 23, 2026

Mulholland, Inc. ("Mulholland," "we," "our," or "us") values your privacy. This Privacy Policy explains how we collect, use, and protect your information when you use our mobile application Brutal and related services (the "Service").

Our Commitment: Data Minimalism. We collect only the minimum information necessary to provide the Service. We do not sell your personal data. We do not serve ads. We do not use third-party advertising SDKs.

1. Information We Collect

1.1 Information You Provide

Account Information: When you create an account, we collect your email address and any authentication credentials you provide.

Communications: If you contact us (e.g., for support), we may collect your name, email address, and the contents of your message.

Payment Information: Subscription fees and Unlock Credit purchases are processed by Apple through the App Store. We receive transaction records indicating that a payment was made and the amount, but we do not receive or store your credit card number, billing address, or other payment details.

1.2 Information Collected Automatically

Screen Time API Data: The Service uses Apple's Screen Time API (Family Controls) to enforce restrictions. This data is processed locally on your device. We do not transmit your app usage logs, browsing history, or notification contents to our servers.

Session Data: We collect information about your focus sessions, including duration, start/end times, completion status, and whether Early Unlock was used.

Unlock Credit Data: We track your Unlock Credit balance (subscription credits and purchased credits), consumption history, and credit tier selections.

Device Information: We may collect device type, operating system version, and unique device identifiers for app functionality.

2. How We Use Your Information

We use the information we collect to:

3. How We Share Your Information

We do not sell your personal information. We may share information in limited circumstances:

Service Providers: We may share information with vendors who help us operate the Service (e.g., cloud hosting, analytics).

Payment Processing: Transactions are processed by Apple. We do not share your payment details with any other third parties.

Legal Compliance: We may disclose information if required by law, court order, or to protect our rights, property, or safety.

Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred.

4. Data Retention

Active Accounts: We retain your information for as long as your account is active or your subscription is in effect.

Inactive Accounts: If you do not use the Service for 24 consecutive months and your subscription has lapsed, we may delete your account.

Transaction Records: Records of payments may be retained for up to 7 years for accounting and legal compliance.

Backup Systems: Deleted data may persist in backups for up to 30 days.

5. Your Rights and Choices

Access and Deletion: You may request access to or deletion of your personal information by contacting privacy@mulholland.ai. We will respond within 45 days.

California Residents (CCPA): You have the right to know what personal information we collect, request deletion, opt out of sales (we do not sell data), and not be discriminated against for exercising these rights.

European Residents (GDPR): You may have additional rights including access, rectification, portability, erasure, and the right to restrict or object to certain processing.

Do Not Track: We do not respond to Do Not Track signals.

6. Security

We use reasonable technical and organizational safeguards to protect your information. In the event of a data breach affecting your personal information, we will notify you within 72 hours of becoming aware of the breach.

7. Children's Privacy

The paid features of the Service (subscriptions and Unlock Credits) are not intended for anyone under 18. The free features are not intended for children under 13. We do not knowingly collect personal information from children under 13.

8. International Users

The Service is hosted in the United States. If you access the Service from outside the U.S., you consent to the transfer of your information to the United States.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the app or by email.

10. Contact Us

Mulholland, Inc.
9062 Rosecrans Ave., Bellflower, CA 90706
privacy@mulholland.ai

Version History

January 23, 2026 — Initial version